Case Summary (G.R. No. 186264)
Summary of the Proceedings
The petitioner filed an action for annulment of a Deed of Sale, claiming that the sale of a portion of land to Respondent Glenda was simulated and without consideration. The Municipal Circuit Trial Court initially ruled in favor of the petitioner, declaring the Deed null and void and reaffirming her ownership. However, Respondents appealed this decision to the Court of Appeals (CA), which eventually reversed the trial court’s ruling, prompting the petitioner to seek redress before the Supreme Court.
Factual Background
The petitioner received the parcel of land from her relatives as a donation and maintained possession and responsibility for tax payments since 1967. She was persuaded by Respondent Glenda to execute a Deed of Absolute Sale in order for the latter to secure a loan. The petitioner contended that this sale lacked any actual consideration and was a mere formality, asserting that the transaction, purportedly executed on August 12, 1967, was never intended to transfer ownership.
Issues Raised in The Case
The primary issue was whether the Deed of Absolute Sale was indeed a simulated contract devoid of legal effect due to lack of consideration. The petitioner argued that there was no true intention to transfer ownership, supported by evidence that she continued to maintain possession and declared the land for taxation purposes under her name until the grievance of the unlawful detainer case arose.
Trial Court's Findings
The Regional Trial Court (RTC) ruled in favor of the petitioner, finding that essential elements indicative of a valid sale were absent, thus categorizing the Deed of Sale as an absolutely simulated contract under Article 1346 of the New Civil Code. The RTC pointed to the absence of consideration, lack of possession by Glenda, and the long duration before the deed was registered as key findings.
Court of Appeals’ Analysis
On appeal, the CA reversed the RTC's decision, asserting that Glenda’s claims regarding the sale’s legitimacy were credible, especially since she had declared the land for taxation and paid realty taxes. The CA emphasized that the notarization of the Deed implied legal regularity, thus supporting the validity of Respondents' claims.
Supreme Court's Ruling
Upon review, the Supreme Court found the CA decision to be based on a misapprehension of facts. The Court reaffirmed the RTC’s position that the sale was indeed simulated, c
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Case Overview
- This case originates from an appeal by certiorari under Rule 45 of the Revised Rules of Court against the Decision of the Court of Appeals (CA) dated August 30, 2007.
- The CA reversed and set aside the trial court's decision, dismissing Dr. Lorna C. Formaran's complaint and ordering her to vacate the land in question.
Factual Background
- Dr. Lorna C. Formaran (petitioner) claims ownership of a parcel of land donated to her by her uncle and aunt, Melquiades Barraca and Praxedes Casidsid, on June 25, 1967.
- On August 12, 1967, under the pretense of assisting Dr. Glenda Ong (respondent) in securing a loan, Dr. Formaran executed a Deed of Absolute Sale for half of the land, which she asserts was fictitious and devoid of consideration.
- Dr. Formaran contends that Glenda Ong filed an unlawful detainer case against her, causing distress and prompting her to seek legal redress.
Proceedings in the Lower Courts
- The Municipal Circuit Trial Court favored Glenda Ong in the unlawful detainer case, which led Dr. Formaran to file for annulment of the Deed of Sale before the Regional Trial Court (RTC) in Kalibo, Aklan.
- The