Case Digest (G.R. No. 209284) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
On March 17, 2005, spouses Dr. Vicente N. Y. Tanchuling and Renee B. Tanchuling executed a Deed of Absolute Sale with respondent Sotero C. Cantela, covering two adjacent parcels of land in Rawis, Legazpi City (Lots 5 and 6 of Block 1, TCT Nos. 41486 and 41487), for a stated consideration of ₱400,000. Although the owner’s copies of the titles were delivered to Cantela, none of the parties took actual physical possession. When petitioners sought the return of the Transfer Certificates of Title, Cantela refused, prompting the Tanchulings to file, on August 6, 2007, a complaint for annulment of the sale and delivery of the titles before the RTC of Legazpi City (Civil Case No. 10659). They alleged that the sale was absolutely simulated because no consideration was paid, the execution of the deed was merely a front to thwart illicit sales by third parties, and Cantela had simultaneously signed an undated deed reconveying the properties back to the Tanchulings. In his answer with compu... Case Digest (G.R. No. 209284) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Execution of Deed and Property Description
- On March 17, 2005, spouses Dr. Vicente Y. Tanchuling and Renee B. Tanchuling executed a Deed of Absolute Sale in favor of respondent Sotero C. Cantela over two parcels (Lots 5 & 6, 192 sq m each) in Rawis, Legazpi City (TCT Nos. 41486 and 41487).
- The Deed recited a consideration of ₱400,000.00, and Sps. Tanchuling delivered the owner’s copies of the TCTs; however, no physical possession of the properties was taken by Cantela, and no evidence of payment was presented.
- Petitioners’ Complaint for Annulment
- On August 6, 2007, Sps. Tanchuling and the heirs of Vicente filed a complaint for annulment of the Deed of Sale and delivery of the TCT duplicates with injunctive relief before the RTC, alleging absolute simulation due to (a) absence of actual consideration, (b) use of the Deed as public deterrent against illegal sellers, and (c) existence of a simultaneous undated Deed reconveying the properties back to the Tanchulings.
- In response, Cantela filed an Answer with Compulsory Counterclaim on February 10, 2008, asserting the validity of the sale, claiming payment of ₱400,000.00, denying the authenticity of the undated Deed (alleging its surreptitious insertion), and referencing attempts to secure tax declarations and compute capital gains tax.
- Decisions of Lower Courts
- RTC Decision (March 23, 2010): Declared the Deed of Sale absolutely simulated and void, citing identical execution features with the undated reconveyance, prolonged delay (1 year, 7 months, 13 days) in title transfer, and absence of actual physical possession or intent to consummate the sale.
- CA Decision (August 30, 2013): Reversed the RTC, finding sufficient proof of consideration (acknowledgment of ₱400,000.00), valid contemporaneous and subsequent acts by Cantela to assert dominion, and prioritizing the notarized Deed over the unnotarized undated instrument.
Issues:
- Whether the Deed of Absolute Sale dated March 17, 2005 is absolutely simulated and, therefore, null and void.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)