Case Summary (G.R. No. 141323)
Antecedent Facts
On January 11, 1988, a deed of absolute sale was executed by David Pelayo to Melki Perez concerning two parcels of land, which was intended to enable Perez to address illegal occupations on the property. However, Lorenza Pelayo, the petitioner’s wife, only signed the deed as a witness, leading to complications when Perez attempted to register the deed. His registration application was denied due to the lack of Lorenza's signature on the first two pages. Following her refusal to re-sign, Perez initiated a complaint for specific performance against both David and Lorenza Pelayo.
Legal Framework
The petitioners argued that the contract was invalid according to Section 6 of RA 6656 (Comprehensive Agrarian Reform Law) which mandates that contracts executed prior to its effectivity must be registered within three months. The trial court sided with the Pelayo couple, declaring the deed null and void due to lack of marital consent and absence of valid consideration. The Regional Trial Court (RTC) ordered the Pelayo couple to compensate Perez for services rendered, viewing the transaction mainly as the settlement of a debt.
Court of Appeals Decision
The Court of Appeals (CA) reversed the RTC decision, positing that Lorenza’s act of signing as a witness implied her consent to the transaction. It held that the petitioners failed to provide sufficient evidence against the presumption that consideration existed for the sale. The CA also underscored David Pelayo's professional background as a lawyer, affirming that he acted with due diligence in executing the transaction. Consequently, it validated the deed and mandated Lorenza to sign it on all pages.
Petitioner's Grounds for Review
In challenging the CA’s ruling, the Pelayo couple contended that the CA overlooked RA 6657's registration mandates, erroneously considered the transaction valid despite compelling evidence of simulation, and improperly inferred implied consent from Lorenza's witnessing of the deed. They further indicated that they were denied due process owing to their inability to submit an appellee's brief due to their counsel’s health issues.
Respondent’s Counterarguments
Melki Perez asserted that the conditions for the validity of the sale had been satisfied, and underscored the CA’s prior ruling which had acknowledged that the transaction did not violate RA 6657 provisions. He argued that Lorenza should have been compelled to sign, thus establishing that her implied consent was evident. Perez also maintained that the CA appropriately rejected the Pelayo couple's late motion for reconsideration for lack of timely filing and substantive merit.
Court’s Findings on Validity of the Deed
The Supreme Court affirmed the CA's conclusions, noting that the validity of the contract had already been established in a previous ruling. The Pelayo couple did not challenge this earlier decision, allowing it to become final. The Court supported the notion that Lorenza's signature as a witness served as implied consent to the sale and viewed her knowledge of the property issues as evidence of her awareness and acceptance of the transaction.
Lack of Marital Consent and Agency
The Court also evaluated the claims regarding lack of marital consent as covered by Articles 166 and 173 of the Civil Code, determining that these provisions do not render the contract void ab initio but mer
...continue readingCase Syllabus (G.R. No. 141323)
Case Overview
- This case pertains to a petition for review on certiorari seeking to reverse the Decision of the Court of Appeals (CA) dated April 20, 1999.
- The CA reversed the prior Decision of the Regional Trial Court (RTC) of Panabo, Davao in Civil Case No. 91-46, which had dismissed the complaint for specific performance filed by Melki Perez against David and Lorenza Pelayo.
- The CA also denied the petitioners' motion for reconsideration on December 17, 1999.
Antecedent Facts
- On January 11, 1988, David Pelayo executed a Deed of Absolute Sale to Melki Perez for two parcels of agricultural land in Panabo, Davao.
- Lorenza Pelayo, David's wife, witnessed the deed but only signed the third page due to her refusal to sign the first two pages.
- Following the refusal to sign, Perez's application for registration of the deed was denied, prompting him to file a complaint against the Pelayo couple for specific performance on August 8, 1991.
Lower Court Proceedings
- The Pelayo couple moved to dismiss the complaint, citing the Comprehensive Agrarian Reform Law (RA 6656), arguing the deed was invalid as it was not registered within three months of the law's effectivity.
- The RTC dismissed the complaint, concluding the deed was null and void due to lack of marital consent and absence of actual consideration.
- The RTC ordered the Pelayo couple to pay Perez a sum of Ten Thousand