Case Summary (G.R. No. 209359)
Relevant Proceedings
This case is a Petition for Review on Certiorari filed under Rule 45 of the Rules of Court. It challenges the decision by the Court of Appeals that reversed the Regional Trial Court's (RTC) Orders which dismissed the respondent's complaint on prescription grounds.
Facts of the Case
Nieves Selerio claimed possession of a 600-square meter parcel of land at Garcia Heights, Davao City. On September 18, 1993, Nieves executed a Deed of Transfer and Waiver of Rights, selling the property to Tregidio Bancasan for a total of PHP 200,000, of which only half was initially paid. The Deed stipulated that Tregidio would pay the remaining amount upon Nieves's vacating the premises by April 30, 1994. A subsequent legal dispute arose when Nieves's alleged illegitimate children contested the property, leading to a Compromise Agreement in 1997 that acknowledged the sale to Tregidio.
Prescription of Action
The primary issue is whether Tregidio's action for recovery of possession has prescribed. The RTC initially ruled that it had prescribed, stating that the cause of action accrued when Nieves failed to vacate the property by the agreed date in 1994. Tregidio filed his complaint on February 28, 2007, more than 12 years after the alleged obligation to vacate.
RTC's Ruling
The RTC found that Tregidio's right to recover the property was based on the Deed, which constituted a contract for specific performance. The court concluded that since the action was filed after the lapse of the ten-year prescription period (per Article 1144 of the Civil Code), the complaint was barred by prescription.
CA's Ruling
The Court of Appeals reversed the RTC's ruling, asserting that the prescriptive period had not elapsed. It classified the transaction as a contract of sale, stating that Tregidio was the rightful owner and that the prescriptive period did not begin until he formally demanded possession in 2007. The CA concluded the petitioners' occupancy of the property after April 30, 1994, was due to Tregidio's tolerance, meaning the action was not barred.
Court's Analysis and Ruling
The Supreme Court agreed with the CA's conclusion regarding the lack of prescription, but the reasoning was different. The Court noted that the RTC erred in its remark regarding the non-existence of a perfected sale due to non-payment and lack of property delivery. It clarified that the essence of a sale is the meeting of consent, and that a contract is perfected once these conditions are met, irrespective of payment.
However, the Court highlighted that issues pertaining to the validity of the
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Background of the Case
- This case is a Petition for Review on Certiorari under Rule 45 of the Rules of Court.
- The petitioners, Nieves Selerio and Alicia Selerio, are contesting the Decision dated March 6, 2015, and Resolution dated November 25, 2015, from the Court of Appeals (CA) in CA-G.R. CV No. 03014-MIN.
- The CA’s ruling reversed previous Orders from the Regional Trial Court (RTC) asserting that the respondent’s action for recovery of possession had not prescribed.
Facts and Antecedent Proceedings
- The primary issue revolves around whether the respondent’s action for recovery of possession has prescribed.
- Nieves Selerio (the claimant) is the occupant of Lot 2, Block 14 in Garcia Heights, Bajada, Davao City, covering 600 square meters.
- On September 18, 1993, Nieves executed a Deed of Transfer and Waiver of Rights, transferring the property to Tregidio Bancasan, acknowledging receipt of 50% of the agreed price of P200,000.00.
- The Deed stipulated that the remaining balance would be paid only after Nieves vacated the premises by April 30, 1994.
- Following this, Jose Selerio and Cecilia Ababo filed a case for partition and accounting against Nieves and Tregidio, which culminated in a Compromise Agreement in 1997 waiving claims to the property.
- On February 2, 2007, Tregidio issued a demand for the petitioners to vacate the property, which they ignored, leading to the filing of a Complaint for Recovery of Possession on February 28, 2007.
Ruling of the Regional Trial Court (RTC)
- The RTC ruled in fav