Case Summary (G.R. No. 104482)
Key Dates
- October 20, 1962: Notarized “absolute” sale of future inheritance by Lazaro to Ricardo and Teresita Taredo
- December 29, 1980: Deed of sale by Lazaro in favor of petitioners (his children) covering his allotted share under extrajudicial settlement
- January 13, 1981: Notarized deed of sale by Lazaro to private respondents covering his undivided 1/12 share
- February 28, 1980: Affidavit of conformity by Lazaro purporting to ratify the 1962 sale
- March 12, 1981: Deed of revocation by Lazaro purporting to annul the petitioners’ sale
- June 7, 1982: Registration of the January 13, 1981 sale in the Registry of Deeds
- July 16, 1982: Filing of petitioners’ complaint for rescission and damages
Applicable Law
- 1987 Philippine Constitution (decision rendered in 1996)
- Civil Code of the Philippines
• Article 1347(2): Contracts on future inheritance are void unless expressly authorized by law
• Article 1544: In cases of multiple sales of immovable property, ownership vests in the purchaser who in good faith first records the title in the Registry of Property
Facts
- Lazaro’s 1962 sale of his future inheritance was later acknowledged to be void under Article 1347 and thus conferred no rights.
- After Matias Taredo’s death and the extrajudicial settlement of his estate, Lazaro acquired actual title to a 1/12 undivided share of Lot No. 191.
- On December 29, 1980, Lazaro sold this share to his ten children (petitioners), evidenced by a private contract and supported by documents expressing Matias’s intent.
- On January 13, 1981, Lazaro sold the same share to Ricardo and Teresita Taredo (private respondents) for ₱10,000, and this deed was registered on June 7, 1982.
- Petitioners never registered their December 1980 deed. They filed suit seeking rescission of the sales in favor of private respondents, alleging bad faith, fraud, and conflicting evidence of intent.
Issues
- Whether a sale of future inheritance is valid.
- Which of two conflicting deeds of sale (December 1980 vs. January 1981) should prevail.
- Whether private respondents registered in good faith and thus acquired ownership despite petitioners’ prior but unregistered sale.
- Whether the Supreme Court may reexamine factual findings on credibility and appreciation of evidence.
Court’s Analysis
• Sale of Future Inheritance: The 1962 contract and the 1980 affidavit of conformity are null and void under Article 1347; they created no rights.
• Competing Sales Post–Extrajudicial Settlement: Both December 1980 and January 1981 deeds relate to the same 1/12 undivided share now free of future-inheritance infirmity.
• Preference by Registration: Under Article 1544, the purchaser of immovable property who in good faith first records the deed in the Registry of Deeds acquires ownership. Private respondents’ January 1981 deed was registered on June 7, 1982; petitioners never registered their deed.
• Good Faith: The Court of Appeals upheld the trial court’s finding that private respondents
Case Syllabus (G.R. No. 104482)
Facts
- On October 20, 1962, Lazaro Taredo executed a notarized deed of absolute sale of “one hectare of whatever share I shall have over Lot No. 191” as future inheritance, in favor of his eldest brother Ricardo M. Taredo and his wife, Teresita Barera Taredo, for ₱1,500.
- Following the death of Lazaro’s father Matias, Lazaro executed on February 28, 1980, an “Affidavit of Conformity” to reaffirm the 1962 sale.
- On December 29, 1980, Lazaro purportedly sold the same Lot No. 191 share to his ten children (petitioners) via an absolute deed of sale.
- On January 13, 1981, Lazaro executed another notarized deed of sale in favor of private respondents, covering his undivided one-twelfth (1/12) share of the same Lot No. 191, for ₱10,000.
- Private respondents registered the January 13, 1981 deed on June 7, 1982; petitioners did not register their December 1980 deed.
- Petitioners filed in July 1982 a complaint for rescission and damages against private respondents, alleging conflicts among the deeds, fraud, and that the 1962 sale was void as a future inheritance sale.
Procedural History
- The trial court (Regional Trial Court, Branch 63, Tarlac) ruled in favor of private respondents, finding petitioners failed to prove their title.
- The Court of Appeals, Thirteenth Division, on September 26, 1991 (CA-G.R. CV No. 24987), affirmed the trial court decision and upheld the good-faith registration of the January 13, 1981 deed. Its May 27, 1992 resolution denied reconsideration.
- Petitioners filed a Petition for Review on Certiorari under Rule 45 before the Supreme Court (G.R. No. 104482), assigned to the Third Division on October 25, 1995.
Issues
- Is a sale of future inheritance valid under Article 1347 of the Civil Code?
- Between multiple sales of the same immovable property, who holds the preferred right to ownership under Article 1544 of the Civil Code?
- What is the probative value of the lower courts’ finding of good faith in the registration of conflicting deeds, and may this Court disturb those factual findings?
Applicable Law
- Article 1347, Civil Code: “No contract may be entered into upon a future inheritance except in cases expressly authorized by law.”
- Article 1544, Civil Code: In cases of multiple sales of immovables, ownership vests in the vendee who in good faith first records the sale in the Registry of Property; absent inscription, possession in good faith; otherwise, oldest title in good faith.
Supreme Court Ruling
- The petition’s assignments of error improperly seek to attack trial court errors rather than the Court of Appeals decision. The petition is thus procedurally misplaced.
- On the merits, the 1962 sale of future inheritance is null and void ab initio, and the 1980 affidavit attempting to ratify it is similarly infirm.
- Both the January 13, 1981 sale (to private respondents) and the December 29, 1980 sale (to petitioners) were free of the future-inheritance defect, since both were executed after the extrajudicial settlement of Matias’s estate.
- Under Article 1544, ownership of the immovable property vested in private respondents, who first registered their deed in good faith on June