Case Summary (G.R. No. 138774)
Factual Background
On August 15, 1983, Gregorio Francisco allegedly executed a deed of absolute sale, transferring two parcels of land to his illegitimate daughters, Regina Francisco and Zenaida Pascual, for the sum of P25,000.00. After Gregorio's death on July 20, 1990, Aida, upon learning about this purported sale, contested its validity, claiming that the signature on the deed was a forgery. In response, the petitioners denied this allegation and contended that the sale was legitimate.
Proceedings in Regional Trial Court
On April 1, 1991, Aida filed a complaint with the Regional Trial Court (RTC) of Bulacan to annul the sale. The RTC ruled in favor of the petitioners on July 21, 1994, upholding the validity of the sale and dismissing Aida's complaint for lack of merit. The decision primarily rested on the credibility of the transaction and the absence of evidence supporting Aida's claims.
Appeal to the Court of Appeals
Following the RTC's dismissal, Aida appealed to the Court of Appeals. On April 30, 1999, the appellate court reversed the RTC's decision, declaring the deed of sale null and void from the beginning. The court found the transaction to be a simulation intended to deprive Aida, the legitimate daughter, of her inheritance rights.
Supreme Court Review and Jurisdiction
The primary issue before the Supreme Court was whether it could review the factual findings of the Court of Appeals. The jurisdiction under Rule 45 of the Revised Rules of Court restricts the Supreme Court’s review to questions of law, not to re-evaluation of evidence unless there is compelling reason to do so.
Findings of Fact and Conclusion
The Supreme Court affirmed the findings of the Court of Appeals, which concluded that the deed of sale lacked consideration and thus was a simulation. The testimonies of the petitioners regarding their financial capability to purchase the property were deemed incredible. Further, the transaction violated the provisions of the Civil Code regarding the legitime of the legitimate child, as it effectively denied Aida her rightful share in her father's estate.
Legal Provisions and Implications
Under Article 888 of the Civil Code, Aida, as the sole legitimate child, was entitled to half of t
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Case Overview
- This case addresses the legal question of whether a legitimate daughter can be deprived of her share in her deceased father's estate through a simulated contract that transfers property to his illegitimate children.
- The case is an appeal via certiorari from a decision of the Court of Appeals which declared a deed of sale void, thereby favoring the legitimate daughter, Aida Francisco-Alfonso.
Parties Involved
- Petitioners: Regina Francisco and Zenaida Pascual, who are the illegitimate daughters of Gregorio Francisco.
- Respondent: Aida Francisco-Alfonso, the sole legitimate daughter of Gregorio Francisco.
Background Facts
- Gregorio Francisco was the owner of two residential parcels of land located in Barangay Lolomboy, Bocaue, Bulacan.
- Aida learned from her father during his hospitalization that the certificates of title for his property were with her half-sisters, Regina and Zenaida.
- Following Gregorio's death on July 20, 1990, Aida discovered that he had sold the land to Regina and Zenaida in 1983 for P25,000.00.
- Aida contended that her father's signature on the deed of sale was forged.
Legal Proceedings
- Aida filed a complaint on April 1, 1991, for annulment of the sale with damages.
- The Regional Trial Court dismissed her complaint on July