Case Summary (G.R. No. L-10474)
Background Facts
After the death of Teodoro Tolete, his widow, Leoncia de Leon, executed an affidavit in July 1948 claiming sole ownership of the estate, which she subsequently sold to Benny Sampilo for P10,000. Benny Sampilo then sold the property to Honorato Salacup for P50,000 in June 1950. However, this sale occurred shortly before Felisa Sinopera initiated legal proceedings to have the estate properly administered, seeking to recover what she asserted as a share belonging to the heirs of the deceased.
Legal Proceedings
Felisa Sinopera filed an action on June 20, 1950, contending that the affidavit executed by Leoncia de Leon had no legal validity, as it was made without involving the other heirs, including nephews and nieces. The notice of lis pendens was recorded after the sale in favor of Honorato Salacup, which raised questions about the validity of the sale transactions.
Court of First Instance Ruling
The Court of First Instance ruled in favor of Felisa Sinopera, declaring the affidavit and subsequent deeds of sale null and void. It awarded her a one-half share of the four parcels of land, stating that Leoncia de Leon’s usufructuary rights over the properties were terminated.
Court of Appeals Decision
Upon appeal, the Court of Appeals affirmed the trial court's decision regarding the annulment of the affidavit but modified the ruling concerning the deeds of sale. The appellate court declared that the annulment of the deeds was premature, stating that they were only void with respect to the portion exceeding what belonged to Leoncia de Leon. The court ordered that one-half of the properties be delivered to Sinopera for proper distribution.
Assignments of Error by Petitioners
The petitioners challenged the appeals court’s ruling on three grounds:
- They claimed that the action was barred because it was filed outside the two-year prescription period set forth in Section 4 of Rule 74 of the Rules of Court.
- They argued that they were innocent purchasers for value, having no knowledge of any claims by the other heirs.
- They contended that the appellate court improperly denied their motion for a new trial.
Analysis of Prescription of Action
The petitioners argued that since the affidavit was registered almost four years prior to the filing, the right of action had lapsed. However, the court clarified that the provisions under Section 4 apply only to those who were notified and participated in the extrajudicial settlement. The court further held that the action was based on fraud related to the misrepresentation by Leoncia de Leon, establishing a four-year period for any claims based on fraud, allowing Sinopera's action to remain valid.
Innocent Purchaser for Value Claim
The Court of Appeals rejected the argument tha
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Case Overview
- The case involves a certiorari petition against a decision of the Court of Appeals affirming a judgment by the Court of First Instance of Pangasinan.
- The original action was brought by Felisa Sinopera, the administratrix of the estate of Teodoro Tolete, seeking to recover one-half share of four parcels of land.
- The dispute centers around the validity of transactions executed by the widow of Teodoro Tolete, Leoncia de Leon, regarding the inheritance of the lands after Tolete's death.
Background Facts
- Teodoro Tolete died intestate in January 1945, leaving behind his widow, Leoncia de Leon, and several nephews and nieces.
- On July 25, 1948, Leoncia executed an affidavit stating that she was the sole heir of Tolete and that he left no other heirs.
- On the same day, she sold the parcels of land to Benny Sampilo for P10,000, which was duly registered.
- Benny Sampilo subsequently sold the land to Honorato Salacup for P50,000, also registered.
- In March 1950, Felisa Sinopera initiated administration proceedings for Tolete's estate and later filed the present action on June 20, 1950.
Legal Proceedings
- A notice of lis pendens was filed on June 26, 1950, which was after the sale to Honorato Salacup.
- The complaint alleged that Leoncia de Leon had no right to execute the affidavit or the deeds of sale, rendering the transactions void.
- Sampilo and Salacup contended that the complaint was barred by the statute of limitations and that they were innocent purchasers for value.