Case Summary (G.R. No. 143325)
Factual Background
Macario and Irene were the owners of six parcels of land, acquired titles for which were executed posthumously after Macario's death without a will in 1972. Their estate was settled via an "Indenture of Extra-Judicial Settlement" by which land titles were transferred to Jose and Erlinda and their mother, Irene. Subsequently, Irene executed an Affidavit of Merger merging these lots into her name, leading to new titles. Irene then married Rolando Relucio in December 1974, which was later annulled due to Rolando's prior marriage.
Key Transactions
Irene sold the six parcels of land to Raul Santos on April 15, 1975, and again sold some of those lots on March 10, 1982, to Raul. Lot No. 612 was sold separately to Greta Tinga de los Reyes. However, throughout each transaction and subsequent marital changes, Irene maintained possession and control over the properties, paying taxes and developing structures such as the "Monica Inn." She later passed away in 1988, after which her adopted children discovered the sales to Raul.
Discovery of Fraud
Upon discovery, Jose and Erlinda questioned the legitimacy of the 1975 deed of sale, leading to an examination by the National Bureau of Investigation which raised concerns about the authenticity of the document. Following these concerns, the heirs initiated legal actions for annulment against various parties, including Raul.
Judicial Proceedings
A lawsuit was filed for the annulment of the sales and titled properties, which culminated in a Joint Judgment from the Regional Trial Court that favored the defendants, upholding the validity of the deeds previously executed by Irene. Following appeals, the Court of Appeals granted a motion for a new trial based on newly discovered evidence, ultimately leading to a ruling that declared the deeds of sale null and void.
Appellants' Arguments
Petitioners, Raul and associated parties, raised issues such as the claimed validity of previous Supreme Court findings on the earlier deeds and argued procedural errors regarding the introduction of new evidence. The court noted that the existence of valid contracts depends on essential elements such as consent and the meeting of minds, which the evidence reportedly failed to substantiate.
Decision of the Court
The Supreme Court ultimately found no merit in the petition, ass
...continue readingCase Syllabus (G.R. No. 143325)
Case Background
- The case involves a petition for review on certiorari filed on July 14, 2000, questioning the Court of Appeals' decision dated November 29, 1999, and its resolution dated May 19, 2000.
- The factual background is derived from the Court of Appeals' narration, focusing on the estate of Macario A. Mariano and Irene PeAa-Mariano, who were owners of six parcels of land.
- The couple had no biological children but had two judicially adopted children, Jose P. Mariano and Erlinda Mariano-Villanueva.
Ownership and Transfers of Property
- Upon Macario's death on December 2, 1972, the ownership of the land passed to his heirs: Irene, Jose, and Erlinda.
- An "Indenture of Extra-Judicial Settlement of Estate" was executed, transferring ownership of the properties, except for Lot 612, which remained solely in Irene's name.
- Irene executed an Affidavit of Merger, merging land titles into her name, despite not being specifically authorized to do so under the indenture.
Marital and Sale Transactions
- Irene married Rolando Relucio on December 9, 1974, but their marriage was annulled due to Rolando's prior existing marriage.
- Irene sold the six parcels of land to Raul Santos on April 15, 1975, for P150,000, but the titles were not transferred immediately.
- Irene sold Lot 612 to Greta Tinga de los Reyes on June 7, 1979, and later sold Lots 545 and 2348 to Raul on March 10, 1982.