Heirs of Biona v. Court of Appeals
REITERATIONFacts
The Antecedents: Ernesto Biona was awarded Homestead Patent No. V-840 over a ten-hectare agricultural land. He and his wife, Soledad Biona, mortgaged this property to secure a loan. After Ernesto's death, Soledad obtained another loan from Leopoldo Hilajos, mortgaging the same property and agreeing that Hilajos would occupy and enjoy the usufruct for two years until the debt was paid. Soledad failed to pay, and Hilajos continued occupying and cultivating the land. On July 3, 1962, Hilajos paid off the original mortgage to the Development Bank of the Philippines. For over twenty-five years, Hilajos peacefully occupied, declared for taxation, paid taxes on, and tenanted the property. On June 19, 1985, the heirs of Ernesto Biona filed a complaint for recovery of ownership, possession, accounting, and damages, alleging unlawful deprivation of use and possession and claiming substantial produce. Procedural History: The Regional Trial Court (RTC) ordered the defendant (Hilajos) to vacate 6/10 of the property and deliver it to Soledad Biona upon payment of P1,000.00 for redemption, and to vacate 4/10 of the property and deliver it to the other heirs, with an accounting of produce. The RTC dismissed Hilajos' counterclaim. The Court of Appeals (CA) reversed the RTC decision, dismissing the complaint and ordering the plaintiffs (Heirs of Biona) to execute a registrable deed of conveyance in favor of Hilajos. The Petition: The Heirs of Biona filed a petition for review on certiorari, assailing the CA's findings on the genuineness and validity of the deed of sale, the application of laches, and the prescription of Hilajos' right of action.
Issue(s)
Whether the signature of Soledad Estrobillo in the deed of sale (Exhibit "2") is genuine and whether the deed of sale (Exhibit 2) is valid and legally conveyed ownership and title over the subject property. Whether the petitioners had lost their right to recover the subject property by virtue of the equitable principle of laches. Whether private respondent's right of action under the deed of sale (Exhibit "2") had prescribed.
Ruling
The Petition is DENIED and the assailed Decision of the Court of Appeals is AFFIRMED.
Ratio Decidendi
On the genuineness and validity of the deed of sale: The Supreme Court affirmed the Court of Appeals' finding that the deed of sale was genuine and valid. The Court noted that Hilajos' categorical statement, corroborated by another witness, that he saw Soledad Biona affix her signature, lent credence to its authenticity. The Court also found that the essential elements for a valid contract of sale were present: a valid object (the property) and a valid consideration (P4,500.00). The fact that the deed of sale was not notarized did not render it null and void, as Article 1358 of the Civil Code regarding public documents is for convenience, not validity. The Court further found that Soledad Biona's signature on the disputed documents (Exhibits 2 and 3) was consistent with her signature on Exhibit 1 (admitted by parties) and Exhibit A (special power of attorney), despite minor variations in printing versus longhand, which were explained by the context of how the documents were prepared. The burden was on the petitioners to prove the contrary, which they failed to do, especially since Soledad Biona herself did not testify to deny her signature. On the application of laches: The Supreme Court found no merit in the petitioners' contention that their right had not prescribed, agreeing with the Court of Appeals that the principle of laches was properly applied. Laches is defined as the failure or neglect to assert a right for an unreasonable and unexplained length of time, warranting a presumption of abandonment or declination to assert it. The Court highlighted that Hilajos had been in possession, occupation, and cultivation of the property as owner since 1960 or 1961, paying taxes, declaring it for taxation, and reaping benefits for over twenty-five years without protest from the heirs, even after they reached the age of majority. The Court emphasized that courts should not favor parties who, by silence and inaction, induce another to invest time, effort, and expense in property for a long period, only to claim title later when the property's value has appreciated. Therefore, notwithstanding any invalidity of the sale concerning the daughters' shares, their inaction for over twenty-five years constituted laches, barring their right to recover the property. On the issue of prescription: The Supreme Court found no merit in the petitioners' contention that their right had not prescribed, agreeing with the Court of Appeals that the principle of laches was properly applied.
Main Doctrine
A deed of sale, even if not notarized, is valid and binding between the parties if all the essential requisites for a contract of sale are present. Furthermore, heirs may lose their right to recover property due to laches, even if the sale was invalid with respect to their shares, if they allowed the vendee to possess and occupy the property as owner for an unreasonable length of time without protest.