Turla v. Heirs of Dayrit
REITERATIONFacts
The Antecedents: Respondents, as heirs of Patrocinio N. Dayrit, filed a complaint for the nullity of two Deeds of Sale (1979 and 1991) and Transfer Certificates of Title (TCT) Nos. 104129 and 104130, and for damages. Patrocinio owned two parcels of land covered by TCT Nos. 40956 and 40967. Patrocinio executed a Conditional Sale on November 11, 1983, with petitioner Ricardo Turla for three parcels of land, including the two mentioned, for P317,000.00, with a P20,000.00 down payment. Ricardo obtained a housing loan secured by a mortgage on the properties. After Patrocinio's death, respondents discovered that the titles to the two parcels were cancelled and reissued in the name of petitioner Rosalinda Z. Turla, based on a Deed of Absolute Sale dated August 17, 1979, and another dated January 11, 1991, both between Patrocinio and Rosalinda. Respondents alleged forgery of Patrocinio's signature in the 1979 deed and claimed ignorance of the sale. Petitioners countered that they complied with the Conditional Sale, paid the balance, and that Patrocinio executed a Deed of Absolute Sale dated January 11, 1991, in favor of Ricardo. They claimed Rosalinda paid the bank loan and Ricardo transferred ownership to her. They blamed a certain Josie Tanhueco for the dubious documents. Procedural History: The Regional Trial Court (RTC) declared the Deeds of Sale dated August 17, 1979, and January 11, 1991, void, cancelled Rosalinda's TCTs, ordered the reinstatement of Patrocinio's TCTs, and awarded damages. The Court of Appeals (CA) affirmed the RTC's decision, finding the deeds fraudulent and the sale without proof of full payment. The Petition: Petitioners sought review from the Supreme Court, arguing that the CA erred in disregarding the presumption of regularity of public documents, in declaring the Conditional Sale inexistent, and in failing to give weight to the Deed of Absolute Sale as proof of full payment.
Issue(s)
Whether the Court of Appeals committed grave abuse of discretion amounting to lack or excess of jurisdiction when it declared that the rule on the presumption of regularity in the execution of public documents cannot be invoked before the Court of Appeals. Whether the Court of Appeals committed grave abuse of discretion amounting to lack or excess of jurisdiction in declaring that a duly signed and notarized Deed of Conditional Sale of Patrocinio Dayrit on November 11, 1983, which was subsequently ratified by his wife, Rita Mina Dayrit, is inexistent. Whether the Court of Appeals committed grave abuse of discretion amounting to lack or excess of jurisdiction when it failed to give weight to the execution of the Deed of Absolute Sale which is tantamount to a full payment of the obligations of the petitioners; and the validity of the Deed of Absolute Sale dated January 11, 1991, executed by Patrocinio in favor of Ricardo, and whether ownership was validly transferred. Whether the sale of conjugal property without the wife's consent renders the sale void or voidable, and the implications for the heirs' claim, considering the principle of relativity of contracts. On the alleged forgery of other deeds and the role of Josie Tanhueco, and the transfer of ownership from Ricardo to Rosalinda.
Ruling
The Supreme Court granted the petition, set aside the CA's decision, and dismissed the complaint for lack of merit. The Court found the Deed of Absolute Sale dated January 11, 1991, executed by Patrocinio in favor of Ricardo to be valid and binding, holding that ownership of the properties was legally transferred to Ricardo. Consequently, Ricardo could validly sell the properties to his sister, Rosalinda. The Court also ruled that the sale of conjugal property without the wife's consent is merely voidable, not void, and that the heirs cannot demand the value of the property in cases of onerous alienations for value.
Ratio Decidendi
On the presumption of regularity: The provided text does not contain a specific ratio decidendi addressing whether the Court of Appeals committed grave abuse of discretion regarding the presumption of regularity. Therefore, this issue cannot be addressed with the provided information. On the Deed of Conditional Sale: The provided text does not contain a specific ratio decidendi addressing whether the Court of Appeals committed grave abuse of discretion regarding the Deed of Conditional Sale. Therefore, this issue cannot be addressed with the provided information. On the Deed of Absolute Sale dated January 11, 1991 (Exh. "20") in favor of Ricardo and the full payment of obligations: The Court found that the purchase price of P317,000.00 stated in the Deed of Absolute Sale was satisfied by Ricardo, as acknowledged by Patrocinio in the deed itself. The Court noted that receipts for payments made to Patrocinio's agent, Roman David, bore Patrocinio's "conforme," and that the total payments, including the down payment, amounted to P80,000.00. The Court concluded that the balance was given to Patrocinio, leading to the execution of the Deed of Absolute Sale, which, being a public instrument, is equivalent to delivery of the property and validly transferred ownership to Ricardo. The Court also found Patrocinio's signature on this deed to be genuine upon visual comparison with his signatures on his passport and SSS ID. On the conjugal nature of the properties, the wife's consent, and the principle of relativity of contracts: The Court reiterated the ruling in Spouses Cueno v. Spouses Bautista that a sale of conjugal real property without the wife's consent is merely voidable, not void, and can only be annulled by the wife during the marriage and within ten years from the transaction, as provided by Article 173 of the Civil Code. Since Rita Mina Dayrit, Patrocinio's wife, did not file an action for annulment during her lifetime or within the prescribed period, the Deed of Sale dated January 11, 1991, in favor of Ricardo remained valid and binding. The Court emphasized that respondents, as heirs, could not invoke Article 166 as only the wife could seek annulment, and they could not demand the value of the property in an onerous sale for value, as it was not considered a fraudulent alienation. The Court applied Article 1311 of the Civil Code, stating that contracts take effect between the parties, their assigns, and heirs. Therefore, respondents, as heirs of Patrocinio, are bound by the Deed of Sale executed by their father in favor of Ricardo. The Court noted that Patrocinio himself never brought an action to nullify the sale during his lifetime, and the respondents filed the case only after his death. On the alleged forgery of other deeds and the role of Josie Tanhueco, and the transfer of ownership from Ricardo to Rosalinda: The Court found the Deed of Sale dated August 17, 1979 (Exh. "E") and the Deed of Sale dated January 11, 1991 (Exh. "F") in favor of Rosalinda to be forged. This conclusion was based on the dissimilarity of Patrocinio's signatures in these deeds compared to his genuine signatures and the fact that both deeds used the same Residence Certificate Number. The Court considered it plausible that Josie Tanhueco, to whom petitioners entrusted documents for title transfer, might have executed these fake deeds without the petitioners' knowledge, especially given Rosalinda's limited education and reliance on Tanhueco. The Court acknowledged that Ricardo, as the new owner of the properties by virtue of the valid Deed of Absolute Sale dated January 11, 1991, could validly sell them to his sister, Rosalinda. This transfer was evidenced by an Absolute Deed of Sale dated June 22, 1996 (Exh. "21"), executed by Ricardo and Myrna in favor of Rosalinda. The Court noted that Rosalinda paid off the PNB loan, leading to the release of the mortgaged properties, and thus the transfer to her name was justified.
Main Doctrine
A sale of conjugal real property entered into by the husband without the wife's consent is merely voidable, not void, and can only be annulled by the wife during the marriage and within ten years from the transaction. If not annulled, the sale is valid and binding. Heirs cannot demand the value of the property in cases of onerous alienations for value, as these are not considered fraudulent dispositions against the wife.