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Nobleza v Nuega

Facts: Respondent Shirley B. Nuega (Shirley) was married to Rogelio A. Nuega (Rogelio) on
September 1, 1990. Upon the request of Rogelio, Shirley sent him money for the purchase of a
residential lot in Marikina where they had planned to eventually build their home. The following year,
or on September 13, 1989, Rogelio purchased the subject house and lot for One Hundred Two
Thousand Pesos (P102,000.00) from Rodeanna Realty Corporation. Shirley claims that upon her
arrival in the Philippines sometime in 1989, she settled the balance for the equity over the subject
property with the developer through SSS8 financing. She likewise paid for the succeeding monthly

On September 1, 1990, Shirley and Rogelio got married and lived in the subject property. The
following year, Shirley returned to Israel for work. While overseas, she received information that
Rogelio had brought home another woman, Monica Escobar, into the family home. She also learned
and was able to confirm upon her return to the Philippines in May 1992, that Rogelio had been
introducing Escobar as his wife.

In June 1992, Shirley filed two cases against Rogelio: one for Concubinage before the Provincial
Prosecution Office of Rizal, and another for Legal Separation and Liquidation of Property before the
RTC of Pasig City. In between the filing of these cases, Shirley learned that Rogelio had the intention
of selling the subject property. Shirley then advised the interested buyers one of whom was their
neighbor and petitioner Josefina V. Nobleza (petitioner) – of the existence of the cases that she had
filed against Rogelio and cautioned them against buying the subject property until the cases are closed
and terminated. Nonetheless, under a Deed of Absolute Sale dated December 29, 1992, Rogelio sold
the subject property to petitioner without Shirley’s consent in the amount of Three Hundred Eighty
Thousand Pesos (P380,000.00), including petitioner’s undertaking to assume the existing mortgage on
the property with the National Home Mortgage Finance Corporation and to pay the real property taxes
due thereon.


 A buyer cannot claim to be an innocent purchaser for value by merely relying on the TCT of the
seller while ignoring all the other surrounding circumstances relevant to the sale
 The nullity of the sale made by Rogelio is not premised on proof of respondent’s financial
contribution in the purchase of the subject property. Actual contribution is not relevant in
determining whether a piece of property is community property for the law itself defines
what constitutes community property.
Sps. Tumbokon v Legaspi


The parcel of land subject in this case was originally owned by the late AlejandraSespeñe,
who had had two marriages. The first marriage was with Gaudencio Franco, by whom she
bore Ciriaca Franco, whose husband was Victor Miralles. The second marriage was with
Jose Garcia, by whom she bore respondent ApoloniaGarcia, who married Primo
Legaspi. Alejandra died without a will in 1935, and was survived by Apolonia and
Crisanto Miralles, the son of Ciriaca (who had predeceased Alejandra in 1924) and Victor
A case was filed by the petitioners for the recovery of ownership and possession of real
property with damages against the respondents. The former alleged that petitioner
Rosario SespeñeTumbokon purchased the land in question from Cresenciana Inog.
Cresenciana Inog, in turn, acquired the land by purchase from Victor Miralles, son-in-law
of decedent Alejandra, who had represented that he inherited the land from his mother-
in-law. The RTC rendered a decision in favor of the petitioners, holding that the spouses
were able to establish the purchase of the land. The Court of Appeals reversed the decision
of the RTC and dismissed the complaint.


Whether or not the sale made by Victor Miralles was valid.


No. The Supreme Court upheld the ruling of the Court of Appeals that Victor’s claim of
being the sole heir was false and erroneous for Alejandra had more than one
intestate heir, and Victor Miralles as a mere son-in-law could not be one of them. A
decedent’s compulsory heirs in whose favor the law reserves a part of the decedent’s
estate are exclusively the persons enumerated in Article 887 of the Civil Code. In the
present case, only two forced heirs survived Alejandra upon her death, namely:
respondent Apolonia, her daughter, and CrisantoMiralles, her grandson.
The lattersucceeded Alejandra by right of representation because his mother, Ciriaca, had
predeceased Alejandra. The petition was denied.

Victor Miralles' supposed acquisition of the land by oral sale from Alejandra had no competent factual
support in the records. For one, the oral sale was incompatible with the petitioners' anchor claim that he
had acquired the land by inheritance from Alejandra. Also, the evidence that the petitioners adduced on
the oral sale was insuf?cient and incredible

Sps. Rex v Parulan