Philippine Supreme Court Case Digests

Case Digests for Philippine Law Students

Marin v. Adil – G.R. No. 47986

Facts:
The Armadas were expecting to inherit some lots from their uncle. Marin had hereditary rights
in the estates of her parents. A deed of exchange was executed wherein it was stipulated that
both parties acknowledge that the exchange operates to their individual and mutual benefit and
advantage, for the reason that the property being ceded, transferred, conveyed and unclaimed
by one party to the other is situated in the place where either is a resident resulting in better
administration of the properties. But the expected land was adjudicated to Soledad, sister of
Marin. So, the Armadas and other heirs sued Soledad for claiming to be the sole heir of their
uncle, but ended in a compromise where the Armadas were awarded two lots. Marin waived,
renounced and quitclaimed her share in her parents’ estate in favour of her another sister
Aurora. She cannot anymore fulfil her obligations in her signed deed of exchange with the
Armadas. The Armadas filed a rescisorry action against Marin.
Issue:
Did Armadas’ action prescribe?
Held:
No. The action to declare contracts void and inexistent does not prescribe. It is evident from the
deed of exchange that the intention of the parties relative to the lots cannot be definitely
ascertained. This circumstance renders the exchange void.
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December 21, 2011

Rongavilla v. CA – G.R. No. 83974

Facts:
The Dela Cruz sisters were the aunts of Dolores Rongavilla. They borrowed P2,000 from the
Rongavillas to have their rooftop repaired. Later, petitioners went back to their aunts to have
them sign a contract. Taking advantage of their lack of education, the sisters were made to
believe that such document, typewritten in English, was just for the acknowledgment of their
debt. After four years, petitioners asked their aunts to vacate the land subject to litigation
claiming that she and her husband were the new owners. After verifying with the Registry of
Deeds, the aunts were surprised that what they have signed was actually a deed of sale. Their
land title was cancelled and the ownership was transferred to their nephews. The land was
mortgaged with the Cavite Development Bank.
Issue:
Was the deed of sale void?
Held:
Yes. While petitioners claimed they were regularly paying taxes on the land in question, they had
no second thoughts stating at the trial and on appeal that they had resorted to doctoring the
price stated in the disputed Deed of Sale, allegedly to save on taxes. While it is true that public
documents are presumed genuine and regular under the Rules of Court, this presumption is a
rebuttable presumption which may be overcome by clear, strong and convincing evidence.

December 21, 2011

Cristobal v. Gomez – G.R. No. 27014

Facts:
Epifanio sold a property with pacto de retro to Yangco. It was stipulated that the property is
redeemable within five years. When the period expired, Yangco extended it. In order to redeem,
Epifanio asked Banas for a loan. Banas agreed, with the condition that Marcelino and Telesfora
be responsible for the loan. The two entered into a private partnership in participation which
stipulated that the property shall be returned to Epifanio as soon as the capital employed have
been covered. Epifanio died. He left Paulina and their children. Marcelino acquired exclusive
rights over the property when Telesfora conveyed her interest to him. Marcelino sold the
property to Banas, with pacto de retro, redeemable within five years. He redeemed it from
Banas. Marcelino submitted a notarial document wherein Epifanio certifies that Marcelino had
requested him to draw up a notarial act showing the properties which Marcelino was known to
be the true owner. Marcelino relies upon this instrument as proving title in him, contending that
Epifanio and his successors are estopped from claiming said lot.

Issue:
Are the heirs of Epifanio estopped from claiming the property?

Held:
No. Estoppel may not be invoked by a person party to the collusion, by reason that he could not
have been misled. The document executed by Epifanio was merely laying the basis of a scheme
to defeat Yangco’s rights under his contract of purchase of 1891, or to defeat Epifanio’s other
creditors.

December 21, 2011

DBP v. CA – G.R. No. 28774

Facts:
DBP bought 91,188.30 square meters of land, consisting of 159 lots, in the proposed Diliman
Estate Subdivision of the PHHC. However, the sale of the lots to DBP, Lots 2 and 4, which form
part of said 159 lots, were still sold by PHHC to the spouses Nicandro, for which 2 deeds of sale
were issued to them by PHHC. Upon learning of PHHC’s previous transaction with DBP, the
spouses filed a complaint against DBP and the PHHC to rescind the sale of Lots 2 and 4 by PHHC
in favor of DBP. The CFI held that the sale of Lots 2 and 4, to DBP is null and void, for being in
violation of Section 13 of the DBP Charter.

Issue:
Do the spouses possess the legal personality to question the legality of the sale?
Held:
Yes. The spouses stand to be prejudiced by reason of their payment in full of the purchase price
for the same lots which had been sold to DBP by virtue of the transaction in question.Thegeneral
rule is that the action for the annulment of contracts can only be maintained by those who are
bound either principally or subsidiarily by virtue thereof. However, a person who is not obliged
principally or subsidiarily in a contract may exercise an action for nullity of the contract if he is
prejudiced in his rights with respect to one of the contracting parties, and can show the
detriment which could positively result to him from the contract in which he had no
intervention.

December 21, 2011

Goldenrod v CA – G.R. No. 126812

Facts:
Barretto owned parcels of land which were mortgaged to UCPB. Barretto failed to pay; the
properties were foreclosed. Goldenrod made an offer to Barretto that it would buy the
properties and pay off the remaining balance of Barretto’s loan with UCPB. It paid Barretto 1
million pesos as part of the purchase price. The remaining balance would be paid once Barretto
had consolidated the titles. On the date that Goldenrod was supposed to pay, Goldenrod asked
for an extension. UCPB agreed. When the extension date arrived, Goldenrod asked for another
extension. UCPB refused. Barretto successfully consolidated the titles. Goldenrod informed
Barretto that it would not be able to push through with their agreement. It asked Barretto to
return the 1 million pesos. Barretto did not give in to Goldenrod’s rescission. Instead, it sold the
property that was part of their agreement to Asiaworld.

Issue:
Should Goldenrod be paid back the 1 million pesos?

Held:
Yes. Rescission creates the obligation to return the things which were the object of the contract
together with the fruits and interest. Barretto is obliged to pay Goldenrod back because 1)
Goldenrod decided to rescind the sale; 2) the transaction was called off and; 3) the property was
sold to a third person. By virtue of the extrajudicial rescission of the contract to sell by
Goldenrod, without opposition from Barretto, who in turn sold it to a third person, Barretto had
the obligation to return the 1 million pesos plus legal interest from the date it received the notice
of rescission.