Case Summary (G.R. No. 188708)
Antecedent Facts
Ildefonso Bartolome and Adelaida Jaro, a married couple and the original owners of the disputed property, sold the property to their daughter, Rosaura Bartolome, for a nominal fee in a deed dated December 31, 1949. This sale was later declared null and void by the Regional Trial Court on the grounds of being simulated. The case stemmed from events where Rosaura subsequently sold portions of the property while acting as guardian for her mother, Adelaida, who was declared incompetent.
Lower Court Rulings
On August 30, 1979, the Regional Trial Court ruled that the deed of sale was simulated and nullified it, thereby redistributing the property among Ildefonso Bartolome's children, including the plaintiffs born of his extramarital relationship. This decision was affirmed by the Intermediate Appellate Court which highlighted the fictitious nature of the sale price and the absence of real consideration, thus justifying the lower court's findings.
Grounds for Appeal
Petitioners raised several issues in their appeal to the Intermediate Appellate Court, including the argument that the trial court erred in nullifying the deed of sale and that prior rulings related to property rights had been disrupted. They also contended that the trial court had confirmed the plaintiffs as children of Ildefonso Bartolome without appropriate procedural requests from them.
Intermediate Appellate Court Findings
The Intermediate Appellate Court upheld the trial court's determination, emphasizing that the validity of the deed of sale had not been previously litigated, thus allowing the current court to review its legitimacy. It ruled that the sale's terms were grossly inadequate, and consequently, declared the deed of sale null and void. Additionally, it found that the house constructed on the property was indeed conjugal property, reaffirming the trial court's findings concerning marital property rights.
Supreme Court Decision
In the resulting appeal to the Supreme Court, the Court dismissed the petition, confirming the findings of the Appellate Court. It reasoned that issues regarding the deed of sale had not been addressed in previous litigation as the private respondents were not parties in that case, thereby maintaining that the current decision held no adverse effects on them. The Supreme Court also clarified that the ackno
...continue readingCase Syllabus (G.R. No. 188708)
Case Background
- This case involves a petition for review on certiorari filed by petitioners Avelino Banaag and his two children, Rosabel and Rowena Banaag.
- The petitioners seek to reverse the decision of the Intermediate Appellate Court (now Court of Appeals) dated October 13, 1986, which affirmed the decision of the Court of First Instance (CFI) of Laguna and San Pablo City in Civil Case No. SP-1105.
- The CFI had declared null and void a deed of sale involving two parcels of land executed by Ildefonso Bartolome and Adelaida Jaro in favor of their daughter Rosaura Bartolome.
Antecedent Facts
- Ildefonso Bartolome and Adelaida Jaro were married and had two children: Rosaura and Guillermo, the latter of whom died young.
- The spouses purchased two parcels of land in San Pablo City in 1946 for P500.00, which were registered under their names.
- In 1949, the spouses sold the same properties to their daughter Rosaura for a mere P1.00, leading to the issuance of Transfer Certificate of Title No. T-582 in her name.
- Rosaura later became the guardian of her mother, Adelaida, and sold part of the properties to the Young Men’s Christian Association (YMCA).
- After Rosaura's death in 1961, Ildefonso became the guardian of Adelaida.
- The children of Rosaura (the petitioners) filed a case (Civil Case No. SP-642) against Adelaida Jaro, which resulted in a compromise agreement recognizing their ownership rights over a portion of the property.