Case Summary (G.R. No. 120600)
Case Background and Filing
On October 7, 1993, the petitioners filed a petition with the Regional Trial Court in Quezon City. The factual background indicates that Louis P. Dawson, during his lifetime, entered into a contract to sell a parcel of land from Siska Development Corporation on May 2, 1967, for P27,632. Dawson died intestate on June 3, 1971, before fully paying the purchase price. After his death, the petitioners, as his heirs, took over the contract and completed the payment by 1978. Despite this, a deed of absolute sale was erroneously executed in favor of the deceased, leading to complications regarding the proper title ownership.
Initial Court Rulings
The Regional Trial Court, in its decision on December 29, 1993, dismissed the petition for cancellation of the title in Dawson's name. The Court of Appeals affirmed this dismissal, citing several reasons, including the nature of the proceedings and questioning the motives for the delay in filing the petition to cancel the title.
Court of Appeals' Findings
The Court of Appeals determined that the summary proceedings under Section 108 of Presidential Decree No. 1529 were not applicable, concluding that the issue largely pertained to estate partition rather than mere title correction. The appellate court criticized the petitioners for only taking action in 1993 and suggested that their motive may have involved tax evasion.
Legal Framework and Arguments
The petitioners contended they were lawful owners of the property after assuming Dawson’s obligations upon his demise. They argued that the contract to sell, by its nature, only transferred title upon full payment, which they fulfilled. They sought to correct the erroneous issuance of the title under Section 108 of PD 1529, which governs the amendment and alteration of certificates of title.
Supreme Court's Ruling
The Supreme Court overturned the Court of Appeals' ruling, holding that petitioners were correct in their reliance on Section 108 of PD 1529. It affirmed that the title to the property should have been transferred to the petitioners as a result of their completion of payment, despite the premature deed executed in favor of Louis P. Dawson, who had already died.
Key Legal Principles
In distinguishing between a contract of sale and a contract to sell, the Court
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Background of the Case
- The case involves a petition for review filed by Ernesto C. Dawson and others (petitioners) against the Register of Deeds of Quezon City and the Judge of the Regional Trial Court of Quezon City, Branch 85 (respondents).
- The petition challenges the February 9, 1995 Decision and the May 29, 1995 Resolution of the Court of Appeals, which upheld the dismissal of the petitioners' request for the cancellation of Transfer Certificate of Title (TCT) No. RT-58706 (248057).
- The petitioners are the heirs of Louis P. Dawson, who passed away intestate on June 3, 1971, before fully paying the price of a parcel of land he had contracted to buy.
Factual Background
- On May 2, 1967, Louis P. Dawson entered into a contract to sell a 638 square meter parcel of land from SISKA DEVELOPMENT CORPORATION for P27,632.00.
- Upon Dawson's death in 1971, his heirs assumed his obligations and completed the full payment of the property by 1978.
- Despite their payment, a Deed of Absolute Sale executed on March 16, 1978, incorrectly transferred the title to the deceased Dawson instead of the petitioners.
- The petitioners filed for the cancellation of the TCT in 1993, stating that the title should reflect their ownership based on their completed payments and legal claims as h