Case Digest (G.R. No. 104482) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Belinda Taredo et al. v. Court of Appeals and Spouses Ricardo M. Taredo and Teresita Barera Taredo, petitioners Belinda Taredo, on her own behalf and representing her siblings, and Teofila Corpuz Tanedo for her minor daughter, Verna, sought to annul multiple deeds of sale executed by their father, Lazaro Taredo, over Lot No. 191 in Gerona, Tarlac. In 1962, Lazaro executed a notarized sale of his “future inheritance” from his parents to respondents Ricardo and Teresita for ₱1,500, which was reaffirmed by an “Affidavit of Conformity” in 1980. After the death of Lazaro’s parents and the extrajudicial settlement vesting actual title, Lazaro sold his undivided one-twelfth share in Lot 191 to respondents by a notarized deed dated January 13, 1981 for ₱10,000, later registered on June 7, 1982. Unbeknownst to respondents, on December 29, 1980 Lazaro had purportedly sold the same share to his ten children via an “Absolute Deed of Sale.” Petitioners filed, on July 16, 1982, a complaint Case Digest (G.R. No. 104482) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Pre-inheritance sale and attempted ratifications
- On October 20, 1962, Lazaro Taredo executed a notarized Deed of Absolute Sale conveying “one hectare of whatever share I shall have over Lot No. 191 …” (future inheritance) to Ricardo and Teresita Taredo for ₱1,500 (Exh. 1).
- On February 28, 1980, after the death of his father Matias, Lazaro executed an “Affidavit of Conformity” reaffirming the 1962 sale (Exh. 3).
- Competing sales after extrajudicial settlement
- December 29, 1980: Lazaro sold his undivided 1/12 share in Lot 191 to his ten children (petitioners) via a private Deed of Absolute Sale (Exh. E).
- January 13, 1981: Lazaro executed a second notarized Deed of Sale of the same undivided 1/12 share in favor of Ricardo and Teresita for ₱10,000, later recorded on June 7, 1982 (Exhs. 4, 5).
- Petitioners’ complaint and evidence
- July 16, 1982: Petitioners filed for rescission of the sales to respondents, presenting evidence of Matias’s intent documents (Exhs. A, B, C).
- Respondents introduced a Deed of Revocation (March 12, 1981; Exh. 6) purporting to revoke the sale to petitioners and Lazaro’s contradictory sworn statements (Exh. G) and testimony acknowledging sale to respondents.
- Judicial findings and appellate review
- The Regional Trial Court held that petitioners failed to prove their title; it found respondents acquired the land in good faith.
- The Court of Appeals affirmed, deeming the 1962 sale void, upholding the January 1981 sale and registration by respondents in good faith.
- This Court granted a Rule 45 petition raising questions on sale of future inheritance, preference among multiple sales, and reviewability of good-faith findings.
Issues:
- Whether a sale of future inheritance is valid under Article 1347 of the Civil Code.
- In cases of multiple sales of the same immovable property, which purchaser has preference in ownership under Article 1544 of the Civil Code.
- The probative value of a lower court’s finding of good faith in registration and the Supreme Court’s power to review such factual determinations in a Rule 45 petition.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)