Case Summary (G.R. No. L-6088)
Property History and Sale Agreement
On December 9, 1938, a homestead patent was issued to Julio Sarabillo, with Original Certificate of Title No. RP-269 later granted. On December 31, 1940, Sarabillo sold part of this land (two hectares) to the Roman Catholic Church for P800, intending for the property to be used for educational and charitable purposes. The sale required the approval of the Secretary of Agriculture and Natural Resources, which was formally solicited in 1947 and granted on March 26, 1949, followed by registration of the deed on March 29, 1950.
Legal Action Initiated
Following Sarabillo's death, Catalina de los Santos discovered the sale contravened Section 118 of Commonwealth Act No. 141, which prohibits the sale of homestead land within five years of receiving the patent. Consequently, she initiated proceedings in the Court of First Instance of Cotabato, seeking to nullify the sale. The defendants claimed the transaction was legal due to its approval and the intended use for charitable purposes.
Court Proceedings and Findings
The trial court directed an appraisal of the improvements on the property, determining their value at P601. The court ruled in favor of de los Santos, declaring the sale null and void, ordering the defendants to vacate the property, and requiring that the purchase price and improvement value be reimbursed to the Roman Catholic Church.
Appeal to Higher Court
Discontent with the trial court's ruling, the defendants appealed, which eventually led to a consideration by the Supreme Court due to the legal questions involved. It was reaffirmed that the sale violated the mandated five-year prohibition, rendering it null and void. The approval received post-sale did not validate the transaction as it did not provide the requisite remedy for past infractions.
Interpretation of Commonwealth Act No. 141
The Supreme Court analyzed the sale's legality under Commonwealth Act No. 141, detailing that not only are the prohibitions mandatory, but the conditions specified, including the timing of approval, must be strictly adhered to. The intention behind these provisions is to uphold public policy, preserving land granted to individuals under the homestead law.
Doctrine of Pari Delicto
The defendants invoked the doctrine of pari delicto, suggesting that both parties were aware of the illegality and thus should not seek judicial relief. However, the court opined that this principle is not absolute and can be set aside when it conflicts with public policy. The court emphasized that de los Santos, as an heir, should not be precluded
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Case Background
- On December 9, 1938, a homestead patent was granted to Julio Sarabillo for a tract of land in Midsayap, Cotabato.
- An Original Certificate of Title No. RP-269 (1674) was issued in Sarabillo's name on March 17, 1939.
- On December 31, 1940, Sarabillo sold two hectares of this land to the Roman Catholic Church of Midsayap for P800, with the sale contingent upon the approval of the Secretary of Agriculture and Natural Resources.
- The Church requested the necessary approval in December 1947, which was granted on March 26, 1949, despite the sale occurring prior to this approval.
Legal Proceedings
- The deed of sale was registered on March 29, 1950, but the Roman Catholic Church did not receive a new title; instead, it was annotated on the original title.
- Following Sarabillo's death, intestate proceedings were initiated, and Catalina de los Santos was appointed as the administratrix of his estate.
- Discovering that the sale violated Section 118 of Commonwealth Act No. 141, de los Santos filed a lawsuit to declare the sale null and void.
Defendants’ Position
- The defendants argued that the sale was legal and valid due to its educational and charitable intent and the subsequent approval by the Secretary of Agriculture and Natural Resources.
- They contended that if the sale were declared null and void, the property would revert to the State, not to the p