Case Summary (G.R. No. 190846)
Key Dates
• Marriage of Jose and Milagros: January 14, 1979
• Deed of Sale and SPA execution: January 13, 1998
• Filing of Annulment Complaint: October 19, 2001
• RTC Decision: December 27, 2006
• CA Decision: August 28, 2009
• CA Resolution denying reconsideration: November 17, 2009
• Supreme Court Decision: February 3, 2016
Applicable Law
- 1987 Philippine Constitution
- Civil Code (Articles 22, 1318, 1458)
- Rules of Court, Rule 128 (Evidence)
- Principle of unjust enrichment
Facts of the Case
During their marriage, Jose and Milagros acquired a house and lot in Tinago, Naga City, titled under TCT No. 21229. Milagros purportedly sold the property to Tomas for ₱200,000 via a deed of sale executed by her as attorney-in-fact under a SPA allegedly signed by Jose. Title was canceled and reissued to Tomas. Unaware of the transaction, Jose, working in Japan, later discovered the sale and filed for annulment, cancellation, reconveyance, and damages, alleging forgery of his signature on the SPA.
Trial Court Ruling
The Regional Trial Court declared the SPA and deed of sale void for lack of spousal consent on a conjugal property sale. It nullified the transaction, awarded Jose temperate damages of ₱20,000, and dismissed the nominal Register of Deeds. Tomas’s cross-claim against Milagros was unresolved due to her default.
Court of Appeals Decision
The Court of Appeals affirmed the nullity of the SPA and deed of sale but:
- Deleted the award of temperate damages.
- Ordered Jose and Milagros to reimburse Tomas ₱200,000 with interest on the principle of unjust enrichment, finding no credible proof of the alleged ₱700,000 payment.
Issues on Appeal
- Whether the deed of sale—being void—may be used to determine the amount of consideration paid.
- Whether Tomas’s uncorroborated testimony suffices to establish that he paid ₱700,000.
Supreme Court Ruling
- Factual Determinations. Questions of fact—such as whether Tomas paid ₱700,000—are beyond certiorari review. The Supreme Court defers to the CA’s finding, which deemed Tomas’s claim unsubstantiated by preponderance of evidence.
- Admissibility of a Void Document. A void contract lacks enforceability but remains admissible to establish what each party gave under it. Under Rule 128, relevance—not validity of a document—governs admissibility. The notarized deed of sale is a public document and prima facie proof of the ₱200,000 consideration.
- Unjust Enrichment. Article 22 of the Civil Code mandates restitution when one party retains benefits at another’s expense without legal ground. Since Tomas gave ₱200,000 under a void sale, unjust enrichment principles require Jose (through Milagros) to
Case Syllabus (G.R. No. 190846)
Procedural History
- Petition for review on certiorari filed with the Supreme Court challenging the Court of Appeals’ (CA) August 28, 2009 decision and November 17, 2009 resolution in CA-G.R. CV No. 88645.
- Original Complaint for Annulment of Sale, Cancellation of Title, Reconveyance and Damages filed by Jose G. Hosana on October 19, 2001 before RTC Branch 62, Naga City, docketed as Civil Case No. 2001-0341.
- RTC Decision of December 27, 2006 declared the sale void for lack of spousal consent, nullified the SPA, and awarded temperate damages of ₱20,000.00 against Tomas P. Tan, Jr. and Milagros C. Hosana.
- CA affirmed nullity of the sale and SPA, deleted temperate damages, and ordered reimbursement of ₱200,000.00 with legal interest under unjust enrichment; denied reconsideration in its November 17, 2009 resolution.
- Supreme Court petition contests the quantum of reimbursement, insisting that Tomas paid ₱700,000.00, not ₱200,000.00.
Facts
- Jose G. Hosana and Milagros C. Hosana, spouses, acquired a conjugal house and lot in Tinago, Naga City (TCT No. 21229).
- On January 13, 1998, Milagros, purportedly as Jose’s attorney-in-fact under a June 10, 1996 SPA, executed a Deed of Sale transferring the property to Tomas for ₱200,000.00; TCT No. 21229 was cancelled and replaced by TCT No. 32568 in Tomas’s name.
- Jose alleged forgery of his SPA signature and lack of his consent; he filed suit naming Milagros, Tomas, and the Register of Deeds as respondents.
- Tomas asserted status as a buyer in good faith and for value, relying on attorney advice and an SPA annot