Distajo v. Court of Appeals
REITERATIONFacts
The Antecedents: The underlying dispute concerns the ownership and partition of seven parcels of land located in Barangay Hipona, Pontevedra, Capiz. Iluminada Abiertas, the mother of several parties, initially owned several of these lots. During her lifetime, she designated her son, Rufo Distajo, as administrator of some of these properties. She subsequently sold portions of Lot No. 1018 to other children, and other lots (Lot Nos. 1046, 1047, 1057) to Rufo Distajo and his daughter, Rhodora Distajo. Additionally, Rufo Distajo acquired Lot Nos. 1001, 1048, 1049, and a portion of Lot No. 1047 from the heirs of Justo Abiertas, Jr., the brother of Iluminada Abiertas. After Iluminada Abiertas' death, several of her heirs demanded possession of these lands from Rufo Distajo and his wife, Lagrimas Soriano Distajo, which was refused, leading to the initiation of legal action. Procedural History: The petitioners, Ricardo Distajo and other heirs of Iluminada Abiertas, filed a complaint with the Regional Trial Court (RTC) of Roxas City on June 5, 1986, seeking recovery of possession and ownership of Lot No. 1018, partition of several other lots, and damages. The private respondent, Lagrimas S. Distajo, filed an answer with a counterclaim. On April 9, 1990, the RTC dismissed the complaint for lack of cause of action, laches, and prescription, and also dismissed the counterclaim. Both parties appealed this decision to the Court of Appeals (CA). On August 21, 1992, the CA rendered a decision modifying the RTC's ruling, ordering the partition of Lot No. 1018, declaring a specific portion for the plaintiffs and the rest for the defendant, and directing the cancellation and issuance of new tax declarations accordingly. A motion for reconsideration filed by the petitioners was denied by the CA on December 9, 1993. The Petition: The petitioners filed a petition for review on certiorari with the Supreme Court, assailing the decision of the Court of Appeals. They argue that Iluminada Abiertas exclusively owned all seven parcels of land and that these should be partitioned among all her heirs. They further contend that Rufo Distajo, as administrator, could not legally acquire the properties under his administration, alleging fraudulent machinations and possible forgery of signatures on the deeds of sale. The petitioners seek to overturn the CA's decision and have the properties partitioned among all heirs of Iluminada Abiertas.
Issue(s)
Whether the sale transactions involving properties administered by Rufo Distajo are void under Article 1491(2) of the Civil Code. Whether the petitioners have established forgery of the deeds of sale. Whether the petitioners have proven fraudulent machinations by Rufo Distajo. Whether the petitioners have a valid cause of action for recovery of possession and ownership, and partition, including claims regarding Lot Nos. 1001, 1048, and 1049.
Ruling
The Supreme Court denied the petition and affirmed the decision of the Court of Appeals. The Court held that the prohibition under Article 1491(2) of the Civil Code is not absolute and does not apply when the principal consents to the sale, which was evidenced by the deeds of sale signed by Iluminada Abiertas. The Court also found no sufficient evidence of forgery or fraudulent machinations. The factual findings of the lower courts, which were affirmed by the Court of Appeals, were given weight.
Ratio Decidendi
On the prohibition under Article 1491(2) of the Civil Code: The Court reiterated that Article 1491(2) of the Civil Code prohibits agents and administrators from acquiring property under their administration. However, this prohibition is not absolute. The provision explicitly states that it does not apply if the principal gives consent to the sale. In this case, the deeds of sale signed by Iluminada Abiertas in favor of Rufo Distajo clearly demonstrated her consent to the transactions. Therefore, the consent of the principal, Iluminada Abiertas, removed the sale transactions from the prohibition contained in Article 1491(2). On the alleged forgery: The Court noted that the petitioners' claim of forgery of Iluminada Abiertas' signatures in the deeds of sale was not substantiated by clear and convincing evidence. No handwriting expert was presented, nor was a witness familiar with Iluminada's signature called to testify. The burden of proving forgery rests on the party alleging it, and such proof must be convincing. On the alleged fraudulent machinations: Similar to the claim of forgery, the petitioners failed to adduce convincing evidence to support their allegations that Rufo Distajo employed fraudulent machinations to obtain Iluminada Abiertas' consent to the sale of the parcels of land. Without sufficient evidence, these claims could not be given weight. On the ownership and partition of the lands, and claims regarding Lot Nos. 1001, 1048, and 1049: The Court affirmed the factual findings of the lower courts, which were binding on the Supreme Court as it is not a trier of facts. Both the RTC and the CA agreed on the ownership of the various lots. The Court of Appeals' clarification on the partition of Lot No. 1018 was upheld, dividing it into a portion belonging to the plaintiffs and the rest to the defendant. The Court emphasized that factual findings of the trial court, if affirmed by the appellate court and not shown to be overlooked or ignored, are binding. The Court noted that Lot Nos. 1001, 1048, and 1049 were owned by Justo Abiertas, Jr., and were sold to Rufo Distajo by his heirs. Therefore, the petitioners, as heirs of Iluminada Abiertas, had no claim over these specific parcels of land. The Court's role is to review errors of law, not to re-examine factual findings unless there is a showing that such findings were arrived at arbitrarily or without basis.
Main Doctrine
The prohibition under Article 1491(2) of the Civil Code against an agent or administrator purchasing property under their administration is not absolute and does not apply if the principal gives consent to the sale, as evidenced by deeds of sale signed by the principal.