Baladad v. Rublico
REITERATIONFacts
The Antecedents: Two parcels of land were registered in the name of Julian Angeles. Julian married Corazon Rublico, who had a son, Sergio Rublico. Julian died, leaving no compulsory heirs except his wife and brother, Epitacio. On February 4, 1985, while on her deathbed, Corazon, along with Epitacio, executed an Extrajudicial Settlement of Estate with Absolute Sale. In this deed, Corazon and Epitacio adjudicated the two lots between themselves, with Corazon receiving three-fourths (3/4) and Epitacio one-fourth (1/4). They then conveyed their respective shares to Cornelia Baladad via absolute sale for ₱107,750.00. Corazon affixed her thumbmark, and Epitacio's share was conveyed by his son, Vicente Angeles, via power of attorney. Corazon died two days later. Subsequently, Sergio Rublico executed an Affidavit of Adjudication by Sole Heir, claiming the same parcels of land. He obtained a new title (TCT No. 155095) and sold the lots to spouses Laureano and Felicidad Yupano for ₱100,000.00. The Yupanos obtained their own titles. Tenants occupying the lots filed an interpleader case, and the RTC declared the Yupanos as the legal owners. Procedural History: Cornelia Baladad filed a complaint for annulment of sale, cancellation of title, and damages, arguing that Sergio knew of the prior sale to her and that the Yupanos were not buyers in good faith. The RTC ruled in favor of Cornelia. The Court of Appeals reversed the RTC decision. Cornelia's motion for reconsideration was denied, leading to the present petition. The Petition: The core issue is the validity of the Extrajudicial Settlement of Estate with Absolute Sale executed by Corazon.
Issue(s)
Whether the Extrajudicial Settlement of Estate with Absolute Sale dated February 4, 1985, is valid. Whether respondent Sergio Rublico had the right to sell the subject properties to the Yupanos. Whether the spouses Yupano were buyers in good faith.
Ruling
The Court reversed and set aside the decision of the Court of Appeals and reinstated the decision of the Regional Trial Court with modifications. The Extrajudicial Adjudication of Estate with Absolute Sale dated February 4, 1985, was declared VALID. The sale between Sergio Rublico and Spouses Laureano Yupano was declared NULL AND VOID, with Sergio Rublico ordered to return the ₱100,000.00 paid by the Yupanos, less expenses for the invalid title. The Register of Deeds was ordered to cancel the Yupanos' titles and restore TCT No. 155768.
Ratio Decidendi
On the validity of the Extrajudicial Settlement of Estate with Absolute Sale: The Court found the deed valid, upholding the RTC's findings. The respondents' argument that Corazon was too weak to consent was debunked by the RTC's observation that a defense witness was inconsistent regarding Corazon's death date. Furthermore, the respondents did not question Corazon's mental state, implying she was of sound mind. The testimony of the notary public, Atty. Francisco, who read and explained the deed to Corazon in Tagalog, was not refuted. The deed itself was clear and unambiguous, negating the need to look beyond its provisions. The absence of Cornelia's signature did not invalidate the sale, as a contract of sale is perfected upon the meeting of the minds on the object and price, and Cornelia's act of bringing the notary public and her subsequent exercise of dominion over the property demonstrated her consent. On whether Sergio Rublico had the right to sell the properties: The Court ruled that Sergio Rublico never had the right to sell the properties because his mother, Corazon, had already sold them to Cornelia before Sergio could inherit any share. The principle of nemo dat quod non habet (one cannot give what one does not have) applies. Sergio's Affidavit of Adjudication by Sole Heir was declared void and without effect. On whether the spouses Yupano were buyers in good faith: The Court found that the Yupanos could not claim to be innocent purchasers for value. It was widely known in the neighborhood and among the tenants that ownership of the lots had been transferred to Cornelia, and her brother Vicente was collecting rentals. The Yupanos lived only a block away and had prior knowledge of these facts. Laureano Yupano knew Cornelia and had even verified that tenants were paying rentals to Vicente before purchasing the property from Sergio. These circumstances should have alerted him to doubt the validity of Sergio's title, but they chose to ignore these indicators, thus failing to be buyers in good faith.
Main Doctrine
The validity of an Extrajudicial Settlement of Estate with Absolute Sale hinges on the presence of consent, object certain, and cause of obligation. A contract of sale is perfected upon the meeting of the minds on the object and price, and the absence of the buyer's signature does not invalidate the sale if the buyer's consent is evident through actions and prior conduct.