Case Summary (G.R. No. 48740)
Summary of Facts
Barbara Sampaga Poblete, the registered owner of Lot No. 29, obtained a loan in October 1997 from a cooperative, mortgaging the lot as collateral. In November 1998, with the intention to sell to Angelito Joseph Maniego for a purported amount of P900,000.00, Poblete executed a Deed of Absolute Sale for P300,000.00, allegedly to evade taxes. However, the sale was marred by complications; Maniego neither paid the entire consideration upfront nor followed through on the purchase.
On 8 June 2000, Maniego sought a loan from Land Bank, using the property as collateral and falsely presenting that the title had been transferred to him via a deed dated 11 August 2000. He subsequently defaulted on the loan, prompting Land Bank to initiate foreclosure proceedings. Poblete filed a complaint for nullification of the deed and reconveyance of title, alleging that the transfer was based on a forged document.
Ruling of the Regional Trial Court
On 28 December 2007, the Regional Trial Court (RTC) ruled in favor of Poblete, declaring both the Deed dated 11 August 2000 and the resulting Transfer Certificate of Title (TCT) No. T-20151 null and void. The RTC found that Maniego did not fulfill the payment obligations for the sale and that the signatures on the deed were forged. The court maintained that Land Bank did not act as a mortgagee in good faith, having failed to exercise necessary due diligence.
Ruling of the Court of Appeals
The Court of Appeals (CA) affirmed the RTC's ruling on 28 September 2010, and its subsequent Resolution on 19 April 2011 upheld the decision against Land Bank, which subsequently sought further review. The CA found the evidence of forgery compelling and supported the RTC’s conclusions regarding the lack of payment and due diligence.
Issues Raised by Petitioner
Land Bank contested several points in its petition for review, challenging the CA's decision on grounds including the validity of TCT No. T-20151, its status as a mortgagee in good faith, and the applicability of the doctrine of "pari delicto," which denotes that parties equally at fault cannot recover damages.
The Court's Ruling on Land Bank's Petition
The Supreme Court denied Land Bank’s petition, emphasizing that the case involved factual findings that were solely within the domain of the lower courts. The court underscored that a deed with forged signatures is null and that Maniego's claim to the title was fraudulent. The court reiterated principles regarding the nature of mortgagees and the heightened diligence requ
...continue readingCase Syllabus (G.R. No. 48740)
The Case
- This case involves a Petition for Review on Certiorari filed by the Land Bank of the Philippines (Petitioner) seeking to reverse the Decision of the Court of Appeals dated September 28, 2010, and its Resolution dated April 19, 2011.
- The Court of Appeals upheld the Regional Trial Court (RTC) of San Jose, Occidental Mindoro's Decision in Civil Case No. R-1331.
The Facts
Parties Involved:
- Petitioner: Land Bank of the Philippines, a banking institution.
- Respondent: Barbara Sampaga Poblete, the registered owner of a parcel of land known as Lot No. 29, with an area of 455 square meters.
Background of the Transaction:
- In October 1997, Poblete obtained a loan of P300,000.00 from Kabalikat ng Pamayanan ng Nagnanais Tumulong at Yumaman Multi-Purpose Cooperative (Kapantay), mortgaging Lot No. 29 as collateral.
- In November 1998, Poblete decided to sell Lot No. 29 to settle her loan and entered into a Deed of Absolute Sale with Angelito Joseph Maniego (Maniego) for P900,000.00, but executed the deed for only P300,000.00 to reduce tax liabilities.
- The Deed dated November 9, 1998, was delivered to Maniego by Balen, Poblete's son-in-law, who did not receive the payment as agreed.
Subsequent Events:
- Maniego paid Kapantay's loan account with Land Bank using Poblete's title.
- On August 11, 2000, Maniego executed another Deed of Absolute Sale, which led to the issuance of Transfer Certificate of Title (TCT) No. T-20151 in his name.
- Land Bank released a loan of P1,000,000.00 to Maniego, which he later defaulted on.
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