Case Summary (G.R. No. 190875)
Factual Background
The original owners of a 126,622 square meter lot covered by Original Certificate of Title (OCT) No. P-489 were Serafin and Salud Adolfo. The property was mortgaged to the Rehabilitation Finance Corporation in 1955, and after default, it was foreclosed and transferred to the Development Bank of the Philippines (DBP). Serafin repurchased the property after the foreclosure and held Transfer Certificate of Title (TCT) No. 6313. In 1975, he allegedly mortgaged the property to Aniceto Bangis without a written agreement. Upon Serafin’s death, his heirs partitioned the property, which was later subdivided and titled in their names. Their attempts to redeem the property from Bangis were met with claims that the transaction was a sale.
Proceedings Before the RTC
In July 2000, the Heirs of Adolfo filed a complaint in the Regional Trial Court (RTC) to annul the alleged deed of sale and assert their rights concerning an antichresis agreement regarding the disputed land. The complaint underwent multiple amendments, reflecting various allegations, including the invalidity of TCT No. T-10567 issued to Bangis. After extensive testimony and the presentation of documentary evidence, the RTC ruled in favor of the Heirs of Adolfo, declaring the transaction between them and Bangis as a mere mortgage and ordering the return of the property upon satisfaction of the mortgage debt.
Court of Appeals Ruling
The Court of Appeals affirmed the RTC's decision, emphasizing that the nature of the transaction was a mortgage rather than a sale. It noted that, despite Bangis possessing the property, the title remained with Adolfo and had not been canceled. The Appellate Court instructed the Heirs of Adolfo to repay the mortgage debt, with interest, but removed the directive to cancel TCT No. T-10567, labeling it a collateral attack.
Legal Issues Presented
The petition for review on certiorari primarily raised the issue of whether the transaction was a sale or a mortgage. The Heirs of Bangis contended that the appellate court erroneously disregarded their presented evidence, including an Extra-Judicial Settlement with an Absolute Deed of Sale. Conversely, the Heirs of Adolfo maintained that the appellate court's rulings were correct and consistent with property law.
Court's Ruling
The Supreme Court denied the petition, attesting that it primarily deals with questions of law, thereby rejecting the factual disputes raised by the Heirs of Bangis. It corroborated the factual findings of the lower courts regarding the nature of the transaction as a mortgage. Specifically, the Court highlighted that essential documentation to support the sale claim was lacking, rendering the purported deeds inadmissible. The Heirs of Bangis failed to provide justifiable secondary evidence for the missing original documents.
Analysis of Property Titles
The Court further held that TCT No. T-10567, allegedly derived from a non-existent earlier title (TCT No. T-10566), was not supported by adequate documentation. The Register of Deeds characterized this title's origin as dubious, thereby favoring the legitimacy of the titles held by the Heirs of Adolfo. The established principle is that the heir with the original title prevails over others claiming possession derived from questionable titles.
Cancellation of TCT No. T-10567
The assessment ruled that the challenge to TCT No. T-10567 constituted a direct attack facilitated by the counterclaim filed by Bangis, countering any claims of a collateral attack against its validity. The Court stated that the indefeasibility principle does not apply to spurious titles and that a thorough examination of the circumstances was warranted.
Prescription of Action
The Heirs of Bangis' assertion that their claim had prescribed was
...continue readingCase Syllabus (G.R. No. 190875)
Case Background
- The case revolves around a dispute concerning ownership and the nature of a transaction involving a 126,622 square meter lot in Valencia, Malaybalay, Bukidnon, originally owned by Serafin and Salud Adolfo.
- The lot was mortgaged to the Rehabilitation Finance Corporation (now Development Bank of the Philippines) in 1955 and was foreclosed due to default.
- Serafin Adolfo repurchased the property in 1971, after the death of his wife in 1970.
Transaction Details
- The core of the dispute is based on a transaction that allegedly took place in 1975 where Serafin Adolfo mortgaged the property to Aniceto Bangis for ₱12,500.00.
- The transaction was not documented in writing, leading to conflicting claims regarding its nature—whether it was a mortgage or a sale.
Proceedings Before the RTC
- The Heirs of Adolfo filed a complaint in 2000 against Bangis for annulment of a deed of sale and to declare the contract as antichresis.
- Various amendments to the complaint were made, including requests for cancellation of TCT No. T-10567 issued in Bangis' name, citing its dubious origin.
- Bangis countered by claiming he purchased the property and had been in open and adverse possession since 1972.
RTC Decision
- The RTC ruled in favor of the Heirs of Adolfo, declaring the contract as a mortgage or antichresis.
- It ordered Bangis to su