Case Summary (G.R. No. 57757)
Proceedings and Relevant Facts
On November 28, 1952, Donata Montemayor mortgaged several parcels of land covered by Transfer Certificate of Title (TCT) No. 2289-Pampanga to secure a loan of P40,900. Subsequently, on December 1, 1963, she mortgaged other properties (TCT Nos. 2887 and 2888) for P35,200. All properties were registered solely under her name and free from encumbrances at the time of the mortgage with PNB.
Foreclosure and Legal Actions
Salvador Vitug, Donata's son, defaulted on his loan, prompting foreclosure on the mortgaged properties, which were subsequently sold at public auction on May 20, 1968. The PNB emerged as the highest bidder, securing the properties through a certificate of sale issued on August 30, 1968. In 1969, PNB sold the properties to individuals including Jesus M. Vitug and others.
Family Dynamics and Legal Disputes
Clodualdo Vitug had two marriages, the first producing three children. His second marriage to Donata resulted in eight children. After Clodualdo's intestate death in 1929, the estate was settled where Donata was appointed administratrix. Legal disputes concerning the property's ownership led Pragmacio and Maximo Vitug to file a complaint for partition and reconveyance of the properties, claiming they were conjugal properties.
Lower Court Decisions and Appeals
Initially, the Court of First Instance dismissed the complaint, prompting an appeal to the Court of Appeals. The appellate court later reversed the lower court's ruling, acknowledging the conjugal nature of the properties and identifying PNB's sale as valid only concerning half of them.
Arguments of the Petitioner
PNB contended that the Court of Appeals erred in its reliance on previous Supreme Court rulings concerning the conjugal nature of the properties, arguing that a special law takes precedence over general laws. PNB further asserted that they were mortgagees in good faith and questioned the legitimacy of the Vitugs' complaints regarding the title, stressing that they were unaware of any claims against the properties when extending the loans.
Supreme Court Decision
The Supreme Court sided with PNB, emphasizing the principle of good faith in dealing with registered land. It underscored that the PNB was
...continue readingCase Syllabus (G.R. No. 57757)
Case Overview
- This case revolves around the issue of whether the presumption of conjugality of properties acquired during the marriage, as provided by Article 160 of the Civil Code, applies to properties covered by a Torrens certificate of title in the name of the widow, Donata Montemayor.
- The petition seeks to review the decision of the Court of Appeals regarding an action for reconveyance and damages initiated by the respondents, Pragmacio and Maximo Vitug.
Factual Background
- On November 28, 1952, Donata Montemayor, through her son Salvador M. Vitug, mortgaged several parcels of land covered by Transfer Certificate of Title (TCT) No. 2289-Pampanga to secure a loan of P40,900.00 from the Philippine National Bank (PNB).
- On December 1, 1963, Donata also mortgaged properties covered by TCT Nos. 2887 and 2888-Pampanga for her son Salvador Vitug's loan of P35,200.00, both mortgages duly registered.
- The properties were all in the name of Donata Montemayor, a widow residing in Pampanga, and were free from liens and encumbrances.
- Subsequent to the failure of Salvador Vitug and others to pay their debts, PNB foreclosed on the properties, which were sold at public auction, with PNB as the highest bidder. New titles were issued in PNB's name.
Procedural History
- On March 21, 1970, Pragmaci