Case Summary (G.R. No. 175483)
Petitioner
Valentina S. Clemente, beneficiary under a special power of attorney, alleged purchaser of Lots 32, 34 and 35-B by deeds of absolute sale dated April 25, 1989.
Respondents
Court of Appeals (Eighth Division) and private respondents Annie S. Jalandoon et al., heirs of Adela de Guzman Shotwell who filed for reconveyance and nullification of the deeds of sale.
Key Dates
– 1985 & 1987: Simulated transfers of Lots 32 and 34 to Carlos Jr. and Dennis, with reconveyance executed April 18, 1989
– April 25, 1989: Deeds of absolute sale of Lots 32, 34 (P250,000) and Lot 35-B (P60,000) to petitioner; special power of attorney granted to petitioner
– September 25, 1989 & October 5, 1990: Registration of petitioner’s titles
– January 14, 1990: Death of Adela de Guzman Shotwell
– July 9, 1990: Complaint filed for reconveyance and nullification (RTC Civil Case Q-90-6035)
– February 26, 2001: RTC Decision nullifying deeds and ordering reconveyance
– August 23, 2005 & November 15, 2006: CA Decision and Resolution affirming nullity for simulation and lack of consideration
– October 14, 2015: Supreme Court Decision denying Rule 45 petition
Applicable Law
– 1987 Philippine Constitution (post-1990 decisions)
– Revised Rules of Court, Rule 45 (certiorari; questions of law only)
– Civil Code: Article 1318 (requisites of contract), Article 1345 (simulation), Article 1471 (simulated price), Article 1453 (resulting trust); Articles on sale formation and consent
Factual Background
Adela owned three contiguous Diliman lots and allowed her children and grandchildren to use them. She previously executed simulated transfers of Lots 32 and 34 to two grandsons (Carlos Jr., Dennis) who reconveyed on demand. On April 25, 1989, Adela purportedly sold all three lots to petitioner for P310,000, simultaneously granting her a broad special power of attorney. Petitioner left with Adela for the United States and, upon return, registered the titles. After Adela’s death, her heirs discovered the deeds and filed for nullity and reconveyance.
Procedural History
The RTC declared the deeds of sale null and void for simulation and lack of consideration, ordered cancellation of titles, and directed petitioner to reconvey. The CA affirmed on the grounds of absolute simulation and absence of consideration, deleting the implied-trust finding. Petitioner filed a Rule 45 petition raising essentially factual issues.
Issue
Whether the deeds of absolute sale dated April 25, 1989 are simulated and unsupported by consideration, rendering them void and inexistent.
Supreme Court Ruling
The petition is denied for lack of a legal question under Rule 45. On the merits (examined for completeness), the deeds are held to be absolutely simulated and without consideration, hence void ab initio; no implied trust arises from an inexistent transfer.
Reasoning – Simulation
– A valid contract requires consent, object, and cause (Art. 1318). Absolute simulation means no intent to be bound.
– Contemporaneous and subsequent acts (letters, petitioner’s obedience to Adela’s orders, retention of control by Adela, the SPA’s administrative powers) demonstrate absence of mutual int
Case Syllabus (G.R. No. 175483)
Procedural History
- The petitioner, Valentina S. Clemente, filed a Petition for Review on Certiorari under Rule 45 of the Revised Rules of Court from the Court of Appeals’ Decision of August 23, 2005 and Resolution of November 15, 2006 in CA-G.R. CV No. 70918.
- The CA had affirmed the RTC of Quezon City, Branch 89, judgment declaring void two deeds of absolute sale between petitioner and her grandmother, Adela de Guzman Shotwell, for being simulated and lacking consideration, but deleted the RTC’s finding of an implied trust.
- Petitioner contended that the CA erred in its factual findings and in disregarding evidence, letters, the special power of attorney, and the number of heirs contesting the sale.
- The Supreme Court rendered its decision on October 14, 2015, denying the petition and affirming the lower courts’ factual findings of simulation and absence of consideration.
Facts of the Case
- Adela de Guzman Shotwell owned three adjoining parcels in Diliman, Quezon City (Lots 32, 34, 35-B), including a “big house” improvement, and allowed her children and grandchildren to use and possess them.
- In 1985 and 1987, Adela simulated transfers of Lots 32 and 34 to grandsons Carlos V. Shotwell, Jr. and Dennis V. Shotwell, who held TCT Nos. 338708 and 366256, respectively, but reconveyed the lots back upon her request.
- On April 18, 1989, the grandsons executed deeds of reconveyance; on April 25, 1989, Adela executed two deeds of absolute sale covering Lots 32 and 34 (price ₱250,000) and, on the same day, a special power of attorney (SPA) in petitioner’s favor.
- Petitioner registered the sales on September 25, 1989, obtaining TCT Nos. 19811 and 19809; Adela died in January 1990.
- In July 1990, Adela’s children discovered the transfers and filed Civil Case No. Q-90-6035 for reconveyance and nullification, later amended to include Lot 35-B based on a deed of sale dated April 25, 1989 (price ₱60,000, registered October 5, 1990).
- The RTC, in a decision promulgated February 26, 2001, declared the deeds null and void, ordered cancellation of titles in petitioner’s name, and directed her to reconvey the thr