Case Summary (G.R. No. 85157)
Background of the Case
The origin of the dispute dates back to July 30, 1956, when the Jao spouses executed a deed of absolute sale transferring ownership of the four hectares of land to spouses Zosimo H. Tan and Elizabeth O. Tan for a nominal price of P1.00, under the understanding that the property was to be utilized as a site for a Chinese Temple, with an obligation to return the property if the temple was not constructed within five years. However, after the specified period elapsed and with no temple erected, the Jao heirs sought reconveyance of the property.
The Issue of Title and Fraud
In 1964, a significant turn of events occurred when a certain Segundina Vda. de Tiongson, fraudulently representing herself as Elizabeth O. Tan, secured a new owner’s duplicate of the property title and subsequently executed a fictitious deed of sale, transferring ownership to herself. Tiongson sold the land to the Bairan spouses, who obtained a new title in good faith.
Previous Legal Proceedings
Three civil cases emerged from this situation:
- Civil Case No. 190 involved a lawsuit by the Tan spouses against Tiongson and the Bairans for nullifying the later title.
- Civil Case No. 390 was filed by the Jao heirs (original owners) against Tan and Tiongson for reconveyance.
- Finally, Civil Case No. C-10228 was initiated by the Jao heirs eighteen years later against the Bairans for annulment of title and reconveyance.
The Trial Court initially ruled in favor of the Jao heirs in Civil Case No. 390, declaring the sale to Tiongson as null and void. However, subsequent rulings from the Court of Appeals and the Supreme Court upheld this judgment.
Court of Appeals Ruling
Despite the prior judgments affirming the Jao family's rights, the Regional Trial Court of Caloocan City ultimately dismissed the complaint filed by the Jao heirs in Civil Case No. C-10228. The Court of Appeals later affirmed this dismissal, leading the petitioners to seek a review from the Supreme Court.
Central Legal Issues
The Supreme Court focused on whether the Bairan spouses could claim a valid title to the property, given that the title they held derived from Tiongson's fraudulent acquisition. The Court determined that knowledge of the earlier court decisions negated any claims of being innocent purchasers for value. The role of good faith was central to the Court's determination, especially given that Tiongson's title and subsequent actions to sell the
...continue readingCase Syllabus (G.R. No. 85157)
Case Citation
- Jurisprudence: 270 Phil. 859
- G.R. No. 85157
- Date: December 26, 1990
- Court: Second Division
Background of the Case
- The case arises from a petition for review on certiorari challenging two decisions from the Court of Appeals:
- A decision dated July 14, 1988, affirming the dismissal of the petitioners' complaint for annulment of title and reconveyance of property.
- A resolution dated September 14, 1988, denying the petitioners' motion for reconsideration.
Parties Involved
- Petitioners: Francisco Jose, Antonio, Erlinda, Jovita, Araceli, Dolores, Virginia, Marta, Ledinia, and Anita, all surnamed Ramon Jao.
- Respondents: Court of Appeals and Laureana C. Vda. de Bairan, as Administratrix of the Estate of Pablo Bairan.
Factual Background
- On July 30, 1956, Pedro Ramon Jao and Catalina Jao executed a deed of absolute sale to spouses Zosimo H. Tan and Elizabeth O. Tan for four hectares of land in Novaliches, Caloocan City.
- The sale was for the nominal consideration of P1.00 and other good and valuable consideration.
- The Jao family claimed the land was merely loaned to the Tans for the potential establishment of a Chinese Temple, to be returned to them if not erected within five years.
- After the five-year period elapsed without the construction of the temple, the Jao family sought reconveyance of the property.
Fraudulent Transactions
- A certain Segundina Vda. de Tiongson impersonated Elizabeth O. Tan, filed for a new owner's duplicate of Transfer Certificate of Title No. 45783, and executed a false deed of sale in her favor, resulting in the cancellation of TCT No. 45783 and issuance of TCT No. 3559 in her name.
- Tiongson subsequently sold the property to