Title
Uy vs. Heirs of Uy-Renales
Case
G.R. No. 227460
Decision Date
Dec 5, 2019
A dispute over the ownership of a lot and building between heirs leads to the Supreme Court declaring a fraudulent Deed of Absolute Sale null and void, ruling in favor of co-ownership between the parties involved.
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Case Digest (G.R. No. 227460)

Facts:

  • The case "Uy v. Heirs of Uy-Renales" involves a dispute over Lot No. 43 and its improvements in Catbalogan, Samar.
  • Petitioners are the heirs of Pablo Uy, and respondents are the heirs of Julita Uy-Renales.
  • The lot was originally registered under Eufronia Labnao, mother of both Pablo Uy and Julita Uy-Renales.
  • Julita died intestate in 1976, and Labnao passed away in 1995.
  • Pablo Uy claimed he inherited half of the property upon Labnao's death, with the other half belonging to Julita's heirs.
  • Pablo Uy discovered that the lot was allegedly sold fraudulently by Labnao to Julita's heirs through a Deed of Absolute Sale dated April 11, 1990.
  • The PNP Crime Laboratory found the signature on the deed to be a forgery.
  • Pablo Uy filed a complaint for nullification of the deed, reconveyance, partition, and damages.
  • Respondents filed a petition for quieting of title, asserting ownership based on the deed.
  • The RTC ruled in favor of the respondents, declaring them owners of the lot and ordering them to pay Pablo Uy the value of half of the building.
  • The CA affirmed the RTC's decision.
  • Pablo Uy appealed to the Supreme Court.

Issue:

  • (Unlock)

Ruling:

  1. The Supreme Court ruled that there was no valid contract of sale between Eufronia Labnao and the heirs of Julita Uy-Renales.
  2. The Supreme Court found that the Deed of Absolute Sale was not ...(Unlock)

Ratio:

  • The Deed of Absolute Sale was not properly notarized, as the notary public did not verify Eufronia Labnao's identity.
  • Lack of proper notarization meant the deed could not be presumed to have been regularly executed.
  • A notarized document does not conclusively establish the validity of a contract of sale; essential elements like consent, object, and price must be present.
  • Testimony from respondent Jessica revealed no meeting of the minds between Labnao and Julita's heirs regarding the sale.
  • Jessica admitted the heirs were surprised by the deed's existence and had no prior agreement with Labnao to purcha...continue reading

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