Case Summary (G.R. No. 259469)
Respondents’ Novation Defense and Possession
Respondents counterclaimed for reconveyance, alleging Robert borrowed 72 g gold in 1983 from Jeffrey. To settle this debt, petitioner allegedly offered the one-hectare parcel plus PHP 8,000; respondents paid consideration, took possession in 1986 with tribal elders’ supervision, and improved the land.
Procedural History
RTC Decision: Recognition of Sale and Dismissal of Recovery Suit
The Regional Trial Court dismissed petitioner’s recovery suit, holding that petitioner sold the one-hectare parcel to extinguish Robert’s debt plus cash, and that petitioner’s inaction for decades amounted to acquiescence. It ordered petitioner to execute a deed of sale.
CA Decision and Resolution: Novation, Statute of Frauds, and Conjugal Consent
The Court of Appeals affirmed. It found (1) a valid novation by substitution of debtor, extinguishing Robert’s loan; (2) the oral sale was partially executed (possession and improvements) and thus exempt from the Statute of Frauds; and (3) under Arts. 166 and 173 of the Civil Code, the sale of conjugal property without the wife’s consent is voidable but binding absent annulment within ten years. Maria did not challenge the sale. A motion for reconsideration was denied.
Issues Presented
Whether there was a valid novation;
Whether the oral sale is unenforceable under the Statute of Frauds;
Whether the sale is void for lack of spousal consent over conjugal property.
Supreme Court Ruling
Valid Novation by Substitution of Debtor
Under Art. 1291 et seq., novation requires creditor consent and clear modification of the obligation. Here, Jeffrey and petitioner agreed to substitute petitioner as debtor, change the object from gold return to land conveyance plus PHP 8,000. Subsequent acts—acceptance of payment and delivery of land—unequivocally established novation.
Partial Execution Exempts Statute of Frauds
Article 1403(2) mandates written form for land sales, but Article 1405 and jurisprudence hold that executed or partially executed contracts are exempt. Delivery of possession, improvements, and payment of consideration constituted partial execution, rendering the oral sale enforceable.
Sale Valid
Case Syllabus (G.R. No. 259469)
Background and Antecedents
- Buyayo Aliguyon is the registered owner of a 31,850-square-meter parcel in Didipio, Kasibu, Nueva Vizcaya (OCT No. P-10995).
- In 1968, Buyayo allowed Kiligge Dummang (father of respondents) to occupy part of the land; Dummang et al. later vacated and returned.
- Upon their return, Dummang et al. requested and obtained from Buyayo’s son, Robert, permission to occupy one hectare of the land.
- Buyayo was absent at the time and only learned of the supposed agreement when Dummang et al. sued Robert for breach of contract to convey the one-hectare parcel as payment for an alleged debt.
Procedural History
- Buyayo filed a Complaint for Recovery of Possession with Damages in the Regional Trial Court (RTC), Bambang, Nueva Vizcaya.
- Dummang et al. filed a Verified Answer and Counterclaim, narrating a 1983 gold-for-loan agreement between Jeffrey Dummang and Robert, and alleging a subsequent oral sale of the one-hectare portion in 1986.
- RTC rendered judgment dismissing Buyayo’s complaint and granting the Dummang counterclaim to reconvey the one-hectare parcel.
- Buyayo appealed to the Court of Appeals (CA); the CA denied relief, upholding novation, partial execution, and the binding nature of the sale despite lack of wife’s consent.
- Buyayo elevated the case to the Supreme Court via Petition for Review on Certiorari under Rule 45, assailing the CA’s Decision (March 23, 2021) and Resolution (March 1, 2022).
Factual Findings
- Jeffrey borrowed 72 grams of gold from Robert in 1983, promising to return identical gold; Robert defaulted.
- Buyayo offered his land to extinguish Robert’s debt, on condition of an additional ₱8,000, which Jeffrey agreed to pay.
- In April/May 1986, tribal elders of the Twali-Ifugao witnessed the agreement; metes and bounds were delineated.
- Dummang et al. took possession, introduced improvements, and a written agreement (allegedly lost) was drawn by a council member.
- Jeffrey attempted barangay conciliation to segregate the one-hectare parcel; proceedings failed.
- Dummang et al. counterclaimed for a Deed of Sale and damages; Buyayo maintained he never co