Case Digest (G.R. No. 214410)
Facts:
- The petitioner is the Technology Resource Center (TRC), previously known as the Technology and Livelihood Resources Center.
- The respondents are the Heirs of Rodolfo Manipol Alvarez, represented by Beatriz Alvarez.
- The case involves a parcel of land identified as Lot No. 4310 in Barrio Maahas, Los Baños, Laguna.
- Respondents filed a complaint on February 19, 2002, seeking annulment of a Real Estate Mortgage, a Deed of Absolute Sale dated May 30, 1978, and Tax Declaration No. 16413.
- The respondents claimed Rodolfo Manipol Alvarez originally owned the property, which he inherited from his parents, Miguel and Vicenta Manipol Alvarez.
- Rodolfo received half of the property, while his sister, Fidela Alvarez Zarate, received the other half.
- After Rodolfo's death in 2001, Beatriz discovered the property was transferred to Pablo and Fidela Zarate through the contested Deed of Absolute Sale.
- The respondents alleged forgery of signatures and improper notarization.
- The spouses Zarate claimed rightful ownership based on the Deed of Absolute Sale and had been paying property taxes since 1994.
- The Regional Trial Court (RTC) dismissed the complaint on March 29, 2011, citing the validity of the Deed of Absolute Sale and the respondents' laches.
- The Court of Appeals (CA) reversed the RTC's decision on April 24, 2014, declaring the Deed of Absolute Sale and mortgage null and void concerning the respondents' share.
Issue:
- (Unlock)
Ruling:
- The Supreme Court denied the petition and affirmed the Court of Appeals' decision.
- The CA's ruling that the principle of laches did not apply was uph...(Unlock)
Ratio:
- The Supreme Court clarified that laches requires specific elements: the complainant's knowledge of the defendant's conduct and an unreasonable delay in asserting rights.
- The respondents became aware of the property transfer only after Rodolfo's death in 2001, negating...continue reading
Case Digest (G.R. No. 214410)
Facts:
The case involves the Technology Resource Center (TRC), formerly known as the Technology and Livelihood Resources Center, as the petitioner, and the Heirs of Rodolfo Manipol Alvarez, represented by Beatriz Alvarez, as the respondents. The dispute centers around a parcel of land identified as Lot No. 4310 located in Barrio Maahas, Los Baños, Laguna. The events leading to the case began when the respondents filed a complaint on February 19, 2002, seeking the annulment of a Real Estate Mortgage, a Deed of Absolute Sale dated May 30, 1978, and Tax Declaration No. 16413 issued by the Municipal Assessor's Office of Los Baños, Laguna. The respondents claimed that the property was originally owned by Rodolfo Manipol Alvarez, who was married to Beatriz Alvarez and had three children. Rodolfo was one of ten children of Miguel Alvarez and Vicenta Manipol Alvarez, who had distributed their properties among their children during their lifetime. The respondents asserted that Rodolfo received a half share of the property, while the other half was given to Fidela Alvarez Zarate, Rodolfo's sister.
After Rodolfo's death in 2001, Beatriz discovered that the property had been transferred to the spouses Pablo and Fidela Zarate through the contested Deed of Absolute Sale. The respondents alleged that the signatures of Miguel and Vicenta on the deed were forged and that the notary public was not duly commissioned. The spouses Zarate, on the other hand, ...