Case Summary (G.R. No. 224567)
Overview of Transactions
The original land title was held by Jose Descutido and Matea Dolduco under Original Certificate of Title No. 31060. On December 10, 1937, they purportedly sold the property to Pedro Diamante, leading to the issuance of Transfer Certificate of Title No. 20491. Subsequently, on June 1, 1940, Diamante transferred ownership to Bonifacia Descutido, resulting in the issuance of Transfer Certificate of Title No. 25284. The legitimacy of these transactions was challenged by Damaso Descutido, one of the original owners’ children, who sought to annul these deeds citing fraud.
Allegations of Fraud
Damaso Descutido filed a complaint arguing that the deeds of sale were fraudulent, fictitious, and lacked valid consideration. He asserted that neither he nor his parents consented to these transactions and that the conveyances were void. The defendants, led by Jacinto Baltazar, contended that they had legal capacity to own the property as good faith purchasers and also claimed that the plaintiffs lacked standing to challenge the sales.
Legal Proceedings and Findings
During the trial, it was established that Jose Descutido, the original owner, had died in August 1944, leaving Damaso and his siblings as heirs. The lower court determined that the deeds of sale were indeed fraudulent. Various parties provided testimony, including assertions from Pedro Diamante and his wife, who claimed that they were misled into signing documents without understanding their implications, thus never receiving any consideration for the alleged sales.
Appellants' Claims and Court's Analysis
In their appeal, the appellants raised multiple errors, including claims that the action was barred due to the passage of time and that the plaintiffs lacked standing. The court noted that the plaintiffs discovered the fraud only in 1950, which was within the four-year limitation period for filing such actions. Regarding standing, it was found that Damaso had rights under a private deed of partition executed on April 30, 1944, which assigned ownership of Lot 790 to him, thus legitimizing his claim.
Findings on Ownership and Legal Effect
The court did not position the private deed of partition as superior to the title held by Bonifacia Descutido; rather, it ruled that both sales were void due to fraudulent circumstances. The court preserved Damaso's ri
...continue readingCase Syllabus (G.R. No. 224567)
Case Overview
- This case involves an appeal from the decision of the Court of First Instance of Iloilo, declaring certain deeds of sale null and void.
- The core issue revolves around the legitimacy of transactions concerning Lot No. 790 of the Cadastral Survey of Dumangas, Iloilo.
Parties Involved
- Plaintiffs/Appellees: Damaso Descutido and Regina Decierdo.
- Defendants/Appellants: Jacinto Baltazar and his children, Pedro Diamante, and Cristina Doctolero.
Background Facts
- Jose Descutido and Matea Dolduco were the original registered owners of Lot No. 790, covered by Original Certificate of Title No. 31060.
- On December 10, 1937, a deed of sale (Exhibit B) was executed, allegedly transferring ownership to Pedro Diamante, leading to the issuance of Transfer Certificate of Title No. 20491.
- On June 1, 1940, another deed of sale (Exhibit C) transferred ownership from Diamante to Bonifacia Descutido, culminating in the issuance of Transfer Certificate of Title No. 25284.
- Jose Descutido passed away in August 1944, leaving behind three children, including Damaso, who later initiated the annulment of the aforementioned deeds.