Case Summary (G.R. No. 171904)
Facts
Rosario Vda. De Andrade owned four parcels of land in Cebu City, which she mortgaged to Simon Diu, leading to a foreclosure. Bobby Tan assisted Rosario in redeeming these properties. Subsequently, Rosario sold these properties to Bobby and her son Proceso Andrade, Jr. for PHP 100,000, documented through a Deed of Absolute Sale. Proceso, Jr. assigned his interest to Bobby via a Deed of Assignment in exchange for PHP 50,000. Bobby also granted Proceso, Jr. an Option to Buy the properties for PHP 310,000, which he did not exercise. This lack of action allowed Bobby to consolidate ownership, receiving Titles in his name.
Initial Judgement
In October 1997, the Andrades filed a complaint for reconveyance and annulment of deeds against Bobby in the Regional Trial Court (RTC). They argued that the transaction was actually an equitable mortgage intended to secure Rosario's debt, claiming co-ownership of the estates. Bobby defended his position, asserting legitimate ownership following Proceso, Jr.'s failure to buy back the properties. On April 6, 2001, the RTC ruled in favor of Bobby, characterizing the sale as valid and reaffirming Bobby's ownership, citing the Andrades' delay in asserting their claim.
Court of Appeals Ruling
The Andrades appealed to the Court of Appeals (CA), which issued a ruling on July 26, 2005. The CA partially affirmed the RTC’s findings, confirming that the transaction was a bona fide sale and dismissing the equitable mortgage claim due to lack of evidence. However, the CA recognized the subject properties as part of the conjugal partnership of Rosario and her late husband, Proceso, Sr. Consequently, it held that Rosario could only sell her pro-indiviso share without affecting the Andrades' interests, thereby establishing a resulting trust and allowing the Andrades to claim their rightful share.
Re-examination of Evidence
Both parties filed motions for reconsideration, which the CA denied. The petition now before the Supreme Court focuses on the characterization of the transactions and whether the properties are exclusive to Rosario or conjugal. The Court emphasized that factual findings of the trial court upheld by the CA are typically conclusive, so the designation of the sale was maintained. In contrast, the question of whether the properties belonged solely to Rosario or were conjugal required further examination.
Legal Standards Applied
The Court referenced Article 160 of the Civil Code, positing that all property acquired during a marriage is presumed conjugal unless proven otherwise. For this presumption to apply, it mus
...continue readingCase Syllabus (G.R. No. 171904)
Case Background
- This case involves consolidated petitions for review on certiorari filed by Bobby Tan and the Andrade family, concerning the ownership and nature of certain parcels of land in Cebu City.
- The initial proceedings were rooted in a complaint for reconveyance and annulment of deeds of conveyance and damages filed by members of the Andrade family against Bobby Tan.
- Central to this dispute are four parcels of land that were originally owned by Rosario Vda. De Andrade, who mortgaged them and later sold them to Bobby Tan.
Facts of the Case
- Rosario was the registered owner of four parcels of land, known as Lots 17, 18, 19, and 20, which she mortgaged to Simon Diu and later foreclosed.
- Bobby Tan agreed to assist Rosario by redeeming these properties, which led to the sale of the properties to him and her son, Proceso Andrade, Jr., for P100,000.00, as documented in a Deed of Absolute Sale dated April 29, 1983.
- On July 26, 1983, Proceso, Jr. executed a Deed of Assignment ceding his rights over the properties to Bobby for P50,000.00, witnessed by Henry Andrade.
- Bobby later provided Proceso, Jr. an Option to Buy the properties, which he ultimately failed to exercise by the deadline of July 31, 1984.
- Following Proceso, Jr.'s failure to act, Bobby consolidated ownership, and Transfer Certificates of Title (TCTs) were issued in his name.
- In 1997, the Andrade siblings filed a complaint arguing that the sale was an equitable mortgage rather than a genuine sale, claiming co-ownership due to the properties being inherited from their father, Proceso Andrade, Sr.
RTC Ruling
- The Region