Download as docx, pdf, or txt
Download as docx, pdf, or txt
You are on page 1of 2

Valdez v CA

G.R. No. 85082


February 25, 1991
Ponente: Gancayco, J.

Facts

1. Francisco and Manuela Ante owned a parcel of land in Quezon City. They executed a
special power in favor of their son, Antonio, to execute any document to mortgage or sell
a portion of the land. Antonio offered to sell the land to Eliseo Viernes, who had been
occupying the lot, with the permission of Ante. Viernes turned down the offer since he
doesn’t have money, so Ante informed the former that he was to sell the lot to Pastor and
Virginia Valdez.
2. Antonio divided the lot into Lot A and Lot B. He sold Lot A first to the petitioners in
June 1980, and then Lot B in February 12 1981. The petitioners demanded that they be
delivered the owner’s duplicate copy of the TCT for the 2 lots. Antonio, though
promising to, failed to deliver the TCT. Meanwhile, the Valdez spouses began putting up
a fence of hollow blocks around the lot, while in front of the Viernes spouses. The latter
was also informed that the Valdez spouses had purchased the land.
3. The petitioners then find out that Ante delivered the owner’s duplicate copy as a
Collateral to Dr. and Mrs. Garma. The petitioners then prod Antonio Ante to tell the
Garma spouses to entrust the duplicate copy to them [petitioners]. The cert of title was
transferred to the petitioners after.
4. When the petitioners proceeded to register the 2 deeds, they find out that their copy had
been declared null and void by a judge order because the Ante spouses had previously
filed a petition for the issuance of a new cert of title and declaring the old one null and
void. Furthermore, the petitioners also discover that new TCTs were issued in the name
of Felicidad since Feb 17, 1982 (only 5 days after the petitioners bought Lot B).
5. The petitioners filed a complaint against them in the RTC of QC seeking the annulment
of the order declaring the earlier TCT null and void, and that they are the owners of the
property. The TC dismissed the petition, but granted actual, moral and exemplary
damages, and attorney’s fees. The petitioners brought the case to the CA who affirmed
the RTC’s decision. Hence, this petition.

Issues

1. W/N the order declaring the TCT null and void should be set aside due to fraud?
(important)
2. W/N the TC and CA erred in their conclusions to the facts of the case? (Our topic)

Disposition

Petition GRANTED.
Rationale

1. YES. Art 1544 of the CC provides that if an, “…immovable property be sold to different
vendees, the ownership shall belong to the person acquiring it who in good faith first
recorded it in the proper registry…” This provision is clear on who should gain
possession of the property is the person acquiring it in good faith first recorded it in the
registry of property. Based on the facts, it is clear that the petitioners were in good faith
when they purchased the 2 lots. The duplicate copy of the owner’s cert of title was just
not delivered to them despite being promised, prompting them to be able to register their
notice of adverse claim over the lots in September 1982. But, the property had already
been assigned to the Vierneses in early February 1982, and Antonio Ante filed for the
nullity of the earlier TCTs. The Vierneses were then able to register the TCT in registry
of deeds in November that same year. The petitioners were clearly the first to purchase
the 2 lots as seen by the dates shown. They filed their adverse claim in the register of
deeds in September, while the Vierneses were able to register the title in the registry of
deeds in November. The petitioners clearly have superior right over the Viernes spouses.

Furthermore, it is clear that Vierneses and the Antes had colluded and were in bad
faith. The Viernesses had already been informed by Ante that he was going to sell the
land to the petitioners. The Viernesses saw the fences being built around the lot and did
not object to them. Moreover, when the adverse claim was filed in the Register of Deeds,
it was effectively PUBLIC notice. Antonio Ante, in collusion, fraudulently made it
appear that the earlier TCT had been lost, and the issuance of a new TCT was needed, as
well as nullifying the earlier one. The fraud was clear as early as July 1981 when
Antonio’s father filed a subpoena requiring Mrs. Garma to produce the ealier TCT. The
Vierneses even admitted to knowing about such filing, meaning they were aware that the
ealier TCT had never been lost.
2. YES. Sec 14 of Art VIII of the states that “No decision shall be rendered by any court
without expressing therein clearly and distinctly the facts and the law on which it is
based.” The TC rendered a 3 page decision where the first 2 pages were just a statement
of the allegations and pleading, as well as, the witnesses presented, and other evidence.
The TC gave its decision afterward stating that the “plaintiffs have failed to prove their
case against the [Viernes] but was able to prove their case against [Ante].” The TC
also said that they couldn’t revoke the Vierneses’ ownership of the land based on good
faith. The CA also made the same mistake by affirming the TC’s decision. The
conclusion given by the TC was arrived at without giving any basis for it. As stated
above, the petitioners were clearly able to prove that they registered the sale earlier than
the Vierneses, so the conclusion of the TC is questionable. The same with CA who also
overlooked the error. The SC has to rely on the factual finding of the lower courts as it is
NOT A TRIER OF FACTS. However, in cases like these, there is no need for the court to
do their own fact finding since it would just delay the case.

You might also like