Case Summary (G.R. No. 236827)
Transaction Background
On April 2, 1979, Angelica A. Lorenzo, the petitioner’s daughter, purchased the subject lot from Lucia under a Deed of Absolute Sale. Following this transaction, the title was transferred to Angelica’s name. Despite this formal transfer, Lucia continued to pay real estate taxes on the property until 1987 and designated Vivian Losaria as the caretaker of the lot, indicating Lucia's ongoing interest in the property.
Heirs and Estate Settlement
Angelica passed away on October 3, 1985, leaving behind her husband, Servillano Sr., and eight children as her heirs. Subsequently, an Extra-Judicial Settlement was executed by the heirs on May 31, 1988, wherein the subject lot was adjudicated to three of the minor children, leading to the cancellation of the title in Angelica’s name and the issuance of a new title in the names of the minors.
Legal Complaint Initiation
On August 3, 1989, Lucia filed a complaint seeking to nullify the Deed of Sale, the estate's settlement, and to recover the property on the grounds that the sale had been simulated merely to facilitate Angelica's housing loan application. The heirs contested this, asserting that the sale was valid and entailed valuable consideration.
Trial Court Decision
The Regional Trial Court (RTC) ruled on October 28, 1993, that the sale was indeed valid, noting Lucia's acknowledgment of Angelica’s ownership through her continued tax payments and offers to sell the property, leading to the dismissal of Lucia’s complaint and imposing attorney's fees on her.
Court of Appeals Review
Dissatisfied with the RTC's decision, Lucia appealed, and the Court of Appeals upheld the findings of the RTC on February 21, 2003, stating that a notarized deed enjoys a presumption of regularity which was not sufficiently rebutted by Lucia. The CA reversed the imposition of attorney’s fees but maintained the dismissal of Lucia's case.
Supreme Court Proceedings
In her appeal to the Supreme Court, the key issue was whether the Deed of Absolute Sale executed by Lucia in favor of Angelica was valid. The petitioners argued the sale was simulated as Angelica and her family did not assert ownership over the property, while the respondents maintained the sale was genuine, supported by subsequent actions acknowledging the sale's validity.
Court's Findings on Simulation
The Supreme Court recognized exceptions to the general rule prohibiting the review of findings of fact by the lower courts. It concluded that the sale was indeed simulated due to a lack of dominion exercised by Angelica and her heirs over the property post-sale, contradicting any claims of valid ownership.
Possession and Ownership Claims
Lucia’s consistent
...continue readingCase Syllabus (G.R. No. 236827)
Case Background
- The case arises from a dispute over a 1,745-square meter parcel of land known as Lot 183-A-1-B-3-A located at Sinsuat Avenue, Rosary Heights, Cotabato City.
- The property was initially registered in the name of Lucia Carlos Aliao under Transfer Certificate of Title (TCT) No. T-15443.
- On April 2, 1979, Lucia's daughter, Angelica A. Lorenzo, purchased the property for P10,000.00, leading to the cancellation of TCT No. T-15443 and the issuance of TCT No. T-15500 in Angelica's name.
- Angelica's heirs executed an Extra-Judicial Settlement of her estate after her death in 1985, adjudicating the property to three minor heirs.
- Lucia continued to pay real estate taxes on the property from 1980 to 1987, despite the title being in Angelica's name.
Procedural History
- Lucia filed a complaint on August 3, 1989, seeking a declaration of nullity for the Deed of Absolute Sale, annulment of the extra-judicial settlement, and reconveyance of the land title.
- The Regional Trial Court (RTC) dismissed the complaint on October 28, 1993, and ordered Lucia to pay P30,000.00 as attorney's fees to Angelica's heirs.
- This decision was affirmed by the Court of Appeals (CA) in a ruling dated February 21, 2003, which also denied Lucia's motion for reconsideration on August 20, 2003.
Core Issue
- The main issue in the case is whether the Deed of Absolute