ASG Law

Category: Civil Law

  • Inheritance Disputes: When Oral Agreements Collide with Property Rights

    In the case of Heirs of Roger Jarque v. Marcial Jarque, the Supreme Court clarified the complexities of property ownership when inheritance, oral agreements, and redemption rights intersect. The Court emphasized that undocumented transfers of property rights, especially in the context of inheritance and co-ownership, require clear and convincing evidence to be legally recognized. This ruling highlights the importance of formalizing property transactions to avoid future disputes.

    Family Feuds: How Unclear Property Lines Led to a Legal Showdown

    The case revolves around a parcel of unregistered land in Sorsogon, originally owned by Laureano Jarque. After Laureano’s death in 1946, the property became subject to inheritance claims from his descendants. The central conflict arose from alleged oral agreements and a subsequent sale with the right to repurchase, leading to a dispute between the heirs of Roger Jarque and the children of Lupo Jarque. The Supreme Court had to determine who had the superior right over the property, considering the Old Civil Code’s provisions on property relations and succession.

    The petitioners, heirs of Roger, argued that their father inherited the land and exercised ownership over it. They claimed that after the death of Laureano and his wife Servanda, an oral partition of the estate occurred, ceding the land to Roger. However, the respondents, children of Lupo, asserted that Servanda sold the land to Benito Coranes with a right to repurchase, which was later exercised by Dominga, Lupo’s daughter, who then transferred her rights to Lelia, one of the respondents. This claim was supported by a Ratification of Ownership of Real Property executed by Dominga. The legal battle thus centered on the validity of these transactions and the impact of the alleged oral partition.

    The Municipal Circuit Trial Court (MCTC) initially ruled in favor of the petitioners, declaring them the rightful owners. The Regional Trial Court (RTC) affirmed this decision. However, the Court of Appeals (CA) reversed the lower courts’ rulings, finding that Servanda had the right to dispose of her share in the conjugal property under the Spanish Civil Code of 1889, which was applicable at the time of Laureano’s death. The CA also held that Dominga rightfully exercised the right of redemption and acquired ownership. The Supreme Court, in its analysis, revisited the property rights under the Old Civil Code and the impact of subsequent transactions.

    Under the Old Civil Code, the default property regime between husband and wife is the conjugal partnership of gains. Upon the death of one spouse, the surviving spouse is entitled to half of the partnership assets, while the other half becomes part of the deceased’s estate, to be inherited by the heirs. The Supreme Court clarified that while Servanda was entitled to her share of the conjugal property, there was no evidence of a formal partition that would have given her the authority to sell the specific property in question. This lack of partition resulted in a co-ownership between Servanda and her children.

    Building on this principle, the Court discussed the concept of partition, noting that it is any act intended to end the indivision among co-heirs. Evidence showed that Roger exercised ownership over the land after Laureano’s death, mortgaging and redeeming it. This established that a partition had occurred, with Roger possessing the land to the exclusion of other heirs. Therefore, at the time of the sale to Benito in 1972, Servanda no longer had the right to sell the land.

    Even if there was no partition, the Court emphasized that Servanda, as a co-owner, could only sell her undivided share. According to Article 493 of the New Civil Code, which reflects Article 399 of the Old Civil Code, a co-owner can alienate their part but cannot sell a specific portion of the common property to the exclusion of other co-owners. The Court quoted Carvajal v. Court of Appeals to underscore this point:

    While under Article 493 of the New Civil Code, each co-owner shall have the full ownership of his part and of the fruits and benefits pertaining thereto and he may alienate, assign or mortgage it, and even substitute another person in its enjoyment, the effect of the alienation or the mortgage with respect to the co-owners, shall be limited, by mandate of the same article, to the portion which may be allotted to him in the division upon the termination of the co-ownership. He has no right to sell or alienate a concrete, specific, or determinate part of the thing in common to the exclusion of the other co-owners because his right over the thing is represented by an abstract or ideal portion without any physical adjudication.

    The Court then addressed the issue of Dominga’s redemption of the property. The respondents claimed that Servanda transferred her right to repurchase the land to Dominga, who then acquired ownership by redeeming it. However, the Court found no evidence to support this claim. The right to repurchase, according to Article 1601 of the New Civil Code, can only be exercised by the vendor or their successors. If a third person redeems the property, they do not become the owner but acquire a lien for the amount advanced.

    In this case, Dominga’s redemption did not transfer ownership to her because there was no proof that Servanda’s right to repurchase was transferred. As such, Dominga’s role was merely that of an agent for Servanda. At most, Dominga only re-acquired the rights previously held by Servanda, such as her aliquot share in the co-ownership. Therefore, Dominga’s actions did not vest in her the title to the land.

    Finally, the Court addressed the respondents’ claim of acquisitive prescription. They argued that they had acquired ownership through extraordinary prescription, which requires uninterrupted adverse possession for 30 years. However, the Court ruled that the respondents’ possession was initially by mere tolerance and only became adverse when Dominga executed the Deed of Ratification of Ownership in 1991. Since Roger asserted his ownership and offered to redeem the property since 1992, the respondents’ possession did not meet the requirement of uninterrupted adverse possession.

    Ultimately, the Supreme Court granted the petition, reinstating the MCTC Decision with modifications to the interest rates. The Court emphasized the need for clear evidence of property transfers, especially in cases involving inheritance and co-ownership. This decision underscores the importance of formalizing property transactions to avoid future disputes among heirs.

    FAQs

    What was the central legal issue in this case? The central issue was determining who had the superior right over the disputed property, considering claims of inheritance, oral partition, and redemption rights. The Court needed to assess the validity of these claims under the Old and New Civil Codes.
    How did the Old Civil Code affect the outcome of the case? The Old Civil Code, which was in effect at the time of Laureano’s death, governed the property relations between Laureano and Servanda, and their successional rights. This code determined the extent of Servanda’s rights over the conjugal property and her ability to dispose of it.
    What is the significance of an oral partition in this case? The petitioners claimed that an oral partition occurred, ceding the property to Roger. The Court recognized that oral partitions can be valid if fully or partly performed, with parties taking possession and exercising ownership.
    What is conventional redemption? Conventional redemption is the right reserved by a vendor to repurchase the thing sold, as stipulated in Article 1601 of the New Civil Code. This right is distinct from the ownership of the property and can only be exercised by the vendor or their successors.
    How does co-ownership affect the right to sell property? Under Article 493 of the New Civil Code, a co-owner can only sell their undivided share in the property. They cannot sell a specific portion to the exclusion of other co-owners until a partition is formally executed.
    What is acquisitive prescription? Acquisitive prescription is a mode of acquiring ownership through possession over a certain period. It can be ordinary (10 years with good faith and just title) or extraordinary (30 years of uninterrupted adverse possession).
    Why was the claim of acquisitive prescription rejected in this case? The claim was rejected because the respondents’ possession was initially by mere tolerance and only became adverse later. Additionally, their possession was not uninterrupted, as Roger asserted his ownership and offered to redeem the property.
    What evidence did the Court find lacking in the respondents’ claims? The Court found a lack of evidence to support the claim that Servanda transferred her right to repurchase the property to Dominga. There was also no evidence of a formal transfer of ownership or a valid basis for acquisitive prescription.

    This case serves as a reminder of the importance of clear and documented property transactions, especially within families. The absence of formal agreements and partitions can lead to protracted legal battles and uncertainty over ownership rights. Proper documentation and legal advice can help prevent such disputes and ensure that property rights are protected.

    For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

    Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
    Source: HEIRS OF ROGER JARQUE VS. MARCIAL JARQUE, G.R. No. 196733, November 21, 2018

  • Reviving Judgments: When Delays Extend the Execution Period Under Philippine Law

    In Maria Perez v. Manotok Realty, Inc., the Supreme Court clarified that the five-year period to execute a judgment by motion can be suspended or interrupted if delays are caused by the judgment debtor. This means that if a party actively prevents the execution of a court decision, they cannot later claim that the winning party’s right to execute has expired. This ruling ensures fairness and prevents parties from using legal maneuvers to avoid fulfilling their obligations.

    Unlocking Justice: How Perez’s Actions Prolonged Manotok’s Wait for Judgment

    This case revolves around a dispute between Maria Perez and Manotok Realty, Inc. concerning unlawful detainer. Manotok Realty initially won a case against Perez in the Metropolitan Trial Court (MeTC), and a decision was rendered in their favor on March 31, 1998. After the decision became final, Manotok Realty sought its execution. However, Perez filed a petition for certiorari before the Regional Trial Court (RTC), attempting to nullify the proceedings in the MeTC case. This action initiated a series of legal challenges that significantly delayed the execution of the initial judgment.

    The parties then entered into a Compromise Agreement, which the MeTC approved on July 15, 1999. Unfortunately, Perez failed to comply with the terms of the agreement, leading Manotok Realty to move for its execution. The MeTC granted this motion on May 4, 2001, ordering the issuance of a writ of execution. However, the sheriff’s attempt to enforce the writ was thwarted by a communication from Perez’s counsel, citing the pending case before the RTC. The RTC eventually dismissed Perez’s petition on May 10, 2004, a decision that was affirmed by the Court of Appeals (CA) and later upheld by the Supreme Court.

    Following the dismissal of Perez’s appeals, Manotok Realty filed a Motion to Enforce Writ of Execution on April 28, 2010. The MeTC initially granted this motion but later reversed its decision, arguing that the 10-year period for enforcing the judgment had lapsed. The RTC, however, reversed the MeTC’s decision, ruling that the delays caused by Perez had interrupted the prescriptive period. This decision was subsequently affirmed by the CA, leading Perez to elevate the matter to the Supreme Court.

    At the heart of the legal debate is Section 6, Rule 39 of the 1997 Rules of Civil Procedure, which states:

    Sec. 6. Execution by motion or by independent action. – A final and executory judgment or order may be executed on motion within five (5) years from the date of its entry. After the lapse of such time, and before it is barred by the statute of limitations, a judgment may be enforced by action. The revived judgment may also be enforced by motion within five (5) years from the date of its entry and thereafter by action before it is barred by the statute of limitations.

    This rule dictates that a judgment can be executed on motion within five years from its finality. After this period, it can only be enforced through a separate action before being barred by the statute of limitations. However, the Supreme Court has recognized exceptions to this rule, particularly when delays are attributable to the judgment debtor.

    Building on this principle, the Supreme Court cited the case of Lancita, et al. v. Magbanua et al., emphasizing that the time during which execution is stayed due to various reasons, including injunctions or appeals, should not be included in calculating the prescriptive period. As the Court noted:

    In computing the time limited for suing out of an execution, although there is authority to the contrary, the general rule is that there should not be included the time when execution is stayed, either by agreement of the parties for a definite time, by injunction, by the taking of an appeal or writ of error so as to operate as a supersedeas, by the death of a party or otherwise. Any interruption or delay occasioned by the debtor will extend the time within which the writ may be issued without scire facias.

    The Supreme Court has consistently applied this principle in numerous cases. In Francisco Motors Corp. v. Court of Appeals, the Court underscored that delays caused by the debtor’s actions effectively suspend the five-year period for enforcing a judgment by motion. The Court has also excluded periods when enforcement was impossible due to restraining orders or lost records. The Court emphasized that it is against good conscience to allow a party to evade their obligations due to strict adherence to technicalities.

    In the present case, the Supreme Court found that Perez’s actions, particularly her filing of petitions and appeals, significantly delayed the execution of the MeTC’s judgment. The sheriff’s report confirmed that the execution was halted due to Perez’s counsel’s communication, citing the pending case before the RTC. Thus, the Court concluded that the five-year period for enforcing the judgment by motion was effectively interrupted by Perez’s actions, which were aimed at delaying the execution for her benefit. The Supreme Court stated:

    Under the circumstances of the case at bar where the delays were caused by petitioner for her advantage, as well as outside of respondent’s control, this Court holds that the five-year period allowed for enforcement of the judgment by motion was deemed to have been effectively interrupted or suspended.

    Ultimately, the Supreme Court denied Perez’s petition and affirmed the CA’s decision. The Court reiterated that the purpose of prescribing time limits for enforcing judgments is to prevent parties from sleeping on their rights and to ensure the efficient administration of justice. Manotok Realty, the Court found, was diligent in pursuing the execution of the judgment in its favor and should not be deprived of the fruits of its victory through mere subterfuge. This case reinforces the principle that parties cannot benefit from delays they themselves cause.

    FAQs

    What was the key issue in this case? The key issue was whether Manotok Realty’s right to execute the July 15, 1999, judgment had expired, and whether the judgment could be executed by motion even after five years.
    What is the general rule for executing judgments? Generally, a judgment must be executed within five years by motion; after that, it requires a separate action before being barred by the statute of limitations.
    When can the five-year period for execution be interrupted? The five-year period can be interrupted when the judgment debtor takes actions that delay or prevent the execution of the judgment.
    What actions by Maria Perez caused delays in this case? Maria Perez caused delays by filing petitions and appeals challenging the validity of the initial MeTC proceedings and the subsequent writ of execution.
    What did the Court of Appeals rule regarding the execution? The Court of Appeals affirmed the RTC’s decision, stating that the delays caused by Perez interrupted the prescriptive period for execution.
    How did the Supreme Court justify its decision? The Supreme Court justified its decision by citing the principle that parties should not benefit from delays they cause and that the purpose of time limits is to prevent parties from sleeping on their rights.
    What is the effect of this ruling on judgment debtors? This ruling means that judgment debtors cannot use legal maneuvers to delay execution and then claim that the creditor’s right to execute has expired.
    What is the practical implication of this case for creditors? The practical implication is that creditors who diligently pursue their rights will not be penalized for delays caused by the debtor’s actions.

    This case underscores the importance of timely action in enforcing court judgments and the principle that parties should not benefit from their own delays. The Supreme Court’s decision in Maria Perez v. Manotok Realty, Inc. serves as a reminder that fairness and equity are paramount in the administration of justice.

    For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

    Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
    Source: MARIA PEREZ, PETITIONER, V. MANOTOK REALTY, INC., RESPONDENT., G.R. No. 216157, October 14, 2019

  • Sale vs. Agency: Distinguishing Estafa in Real Estate Transactions

    In a significant ruling, the Supreme Court clarified the distinction between a contract of sale and agency in real estate transactions, particularly in relation to the crime of estafa. The Court emphasized that for estafa to exist, there must be a clear misappropriation or conversion of funds received in trust, which is absent when a transaction is a genuine sale transferring ownership. This distinction is crucial for determining criminal liability in cases where proceeds from property sales are not fully remitted to the original owner.

    When a Real Estate Deal Turns Sour: Sale or Betrayal?

    This case revolves around a real estate deal gone wrong, testing the boundaries between a simple sale agreement and a breach of trust. The central question is whether the failure to remit proceeds from a property sale constitutes estafa, or simply a breach of contract remediable through civil action. The petitioner, Danilo S. Ibañez, was accused of estafa for allegedly misappropriating proceeds from the sale of a property owned by spouses Arturo and Honorata Pineda. The Regional Trial Court (RTC) and the Court of Appeals (CA) initially convicted Ibañez, but the Supreme Court reversed these decisions, acquitting him of the crime.

    The dispute originated from a Memorandum of Agreement (MOA) between Ibañez and the Pinedas, where Ibañez was authorized to sell the Pinedas’ three-hectare orchard for P6,000,000.00. Ibañez sold various lots, collecting P2,513,544.00, but only remitted P860,166.45 to the Pinedas, leaving a balance of P647,560.00. The Pinedas filed a complaint for estafa, alleging that Ibañez misappropriated the funds. The RTC and CA sided with the Pinedas, viewing the transaction as an agency agreement where Ibañez failed to fulfill his duty to remit the proceeds. However, the Supreme Court disagreed, asserting that the MOA constituted a contract of sale, not agency.

    The Supreme Court underscored the importance of interpreting contracts based on their literal terms. Article 1370 of the Civil Code provides:

    Article 1370. If the terms of a contract are clear and leave no doubt upon the intention of the contracting parties, the literal meaning of its stipulations shall control.

    The MOA explicitly stated that the Pinedas “sells, transfer[s] and convey[s]” the property to Ibañez, indicating a clear intention to enter into a contract of sale. The Court also invoked the parol evidence rule, which prohibits the introduction of extrinsic evidence to contradict the terms of a written agreement. Section 9, Rule 130 of the Rules of Court states:

    SEC. 9. Evidence of written agreements. — When the terms of an agreement have been reduced to writing, it is considered as containing all the terms agreed upon and there can be, between the parties and their successors in interest, no evidence of such terms other than the contents of the written agreement.

    According to the Supreme Court, the lower courts erred in admitting the Pinedas’ claim that the MOA was a simulated contract of sale. As Atty. Pineda did not testify to affirm the complaint-affidavit, it remained inadmissible hearsay evidence. The Court also addressed the CA’s reliance on Ibañez’s testimony, clarifying that the actions of both parties did not point to an agency relationship. In essence, the Court found no evidence suggesting that Ibañez was acting merely on behalf of the Pinedas.

    The Court distinguished the elements of estafa under Article 315, par. 1(b) of the Revised Penal Code, which requires proof that the accused received money or property in trust or under an obligation to return it. The Supreme Court emphasized that the crime of estafa requires the following elements to concur:

    (1) receipt of items in trust or under an obligation to return them or the proceeds of an authorized transaction; (2) misappropriation, conversion for personal benefit or denial of such receipt; (3) entrustor or owner was prejudiced; and (4) demand was made by the offended party.

    Because the transaction was a sale, Ibañez received the property not as an agent, but as a vendee. The failure to pay the full consideration made the Pinedas unpaid vendors, not victims of estafa. Thus, the Court highlighted that in this kind of estafa, the fraud which the law considers as criminal is the act of misappropriation or conversion. Consequently, when the element of misappropriation or conversion was missing, or was not established, there could be no estafa. Moreover, the prosecution failed to prove that Ibañez had misappropriated or converted the funds for personal use, a critical element for establishing estafa.

    The Court underscored that:

    The settled rule is that conviction can be handed down only if every element of the crime was alleged and proved.

    Despite acquitting Ibañez of estafa, the Court acknowledged his civil liability. Based on the amicable settlement, Ibañez was obligated to remit 60% of the total sales to the Pinedas, a balance of P647,960.00, plus interest, remained unpaid. The Court ordered Ibañez to pay this amount, plus interest, from the filing of the information until full payment.

    This case provides a clear framework for differentiating between sales and agency agreements in real estate transactions. It reinforces the principle that estafa requires a clear breach of trust involving misappropriation or conversion of funds. In cases where the transaction is a sale, the failure to pay the full purchase price does not constitute estafa, but rather a civil obligation.

    FAQs

    What was the key issue in this case? The key issue was whether the failure to remit proceeds from a real estate sale constituted estafa or a breach of contract, focusing on the distinction between a contract of sale and an agency agreement. The Court needed to determine if the accused had misappropriated funds or simply failed to fulfill a payment obligation.
    What is estafa as defined in this case? Estafa, in this context, involves misappropriating or converting money or property received in trust or under an obligation to return it, to the prejudice of the owner. The prosecution must prove that the accused acted with abuse of confidence and converted the funds for personal gain.
    What is the parol evidence rule? The parol evidence rule states that when an agreement has been reduced to writing, the terms of that agreement cannot be contradicted or varied by external evidence. This rule ensures that the written contract is considered the complete and final expression of the parties’ agreement.
    How did the Court distinguish between a sale and an agency? The Court distinguished between a sale and an agency by examining the intent of the parties as expressed in the written agreement. In a sale, ownership of the property transfers to the buyer, while in an agency, the agent acts on behalf of the principal without gaining ownership.
    What was the significance of the Memorandum of Agreement (MOA)? The MOA was critical because it outlined the terms of the agreement between Ibañez and the Pinedas. The Court interpreted the MOA’s language as indicative of a sale, as it stated the Pinedas “sells, transfer[s] and convey[s]” the property, showing intent to transfer ownership.
    Why was the complaint-affidavit of Atty. Pineda deemed inadmissible? The complaint-affidavit was deemed inadmissible because Atty. Pineda did not testify to confirm its execution and contents. Without his testimony, the affidavit remained hearsay evidence, which is not admissible in court.
    What civil liability did Ibañez incur? Despite being acquitted of estafa, Ibañez was held civilly liable for the unpaid balance of P647,960.00 based on the amicable settlement between the parties. The Court ordered him to pay this amount, plus interest, from the date the information was filed.
    What are the implications of this ruling for real estate transactions? This ruling clarifies that failing to remit proceeds from a property sale does not automatically constitute estafa. It emphasizes the need to carefully distinguish between sales and agency agreements and to prove actual misappropriation or conversion of funds for criminal liability to arise.

    The Supreme Court’s decision in this case underscores the necessity of clear contractual language and the importance of distinguishing between the obligations arising from sales and agency agreements. This distinction is essential for determining whether a failure to remit funds constitutes a civil breach or a criminal offense.

    For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

    Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
    Source: Danilo S. Ibañez vs. People of the Philippines, G.R. No. 198932, October 09, 2019

  • Death Abates Criminal Liability: Extinguishment of Penalties and Civil Obligations in Criminal Proceedings

    In a pivotal ruling, the Supreme Court has clarified that the death of an accused individual prior to the finality of their conviction effectively extinguishes their criminal liability, and consequently, any civil liability arising solely from the crime. This decision underscores the fundamental principle that criminal penalties are personal and cannot be imposed upon a deceased individual’s estate. While civil liabilities directly linked to the criminal act are also extinguished, the ruling preserves the right of victims to pursue separate civil actions against the estate of the deceased based on other sources of obligation, such as contracts or quasi-delicts, ensuring that justice may still be sought through alternative legal avenues.

    The Abatement: When Death Nullifies Justice?

    The case of People of the Philippines v. Norieto Monroyo y Mahaguay (G.R. No. 223708) presents a somber intersection of justice and mortality. Norieto Monroyo y Mahaguay was found guilty by the Court of Appeals of multiple counts of Acts of Lasciviousness and one count of Qualified Rape. The Supreme Court initially affirmed this decision with modifications. However, before the judgment became final, accused-appellant Norieto Monroyo y Mahaguay passed away. This event triggered a reevaluation of the case, leading the Supreme Court to consider the legal implications of the accused’s death on the criminal and civil liabilities arising from the charges against him. The primary legal question before the Court was whether the death of the accused-appellant extinguished his criminal and civil liabilities.

    The Supreme Court anchored its decision on Article 89(1) of the Revised Penal Code, which explicitly states that criminal liability is totally extinguished by the death of the convict, particularly concerning personal penalties. Furthermore, regarding pecuniary penalties, the liability is extinguished if the offender’s death occurs before the final judgment. The Court reiterated this principle, emphasizing that with the death of the accused-appellant, the criminal action is extinguished because there is no longer a defendant to stand as the accused. The civil action instituted within the criminal case for the recovery of civil liability ex delicto is also extinguished, as it is grounded on the criminal action.

    However, the Court clarified that the civil liability of the accused-appellant might be based on sources other than delicts. This distinction is vital because it preserves the rights of the victims, AAA and BBB, to pursue separate civil actions against the estate of the accused-appellant, as warranted by law and procedural rules. The Supreme Court, in People v. Culas, thoroughly explained the effects of the death of an accused pending appeal on his liabilities:

    From this lengthy disquisition, we summarize our ruling herein:

    1. Death of the accused pending appeal of his conviction extinguishes his criminal liability[,] as well as the civil liability[,] based solely thereon. As opined by Justice Regalado, in this regard, “the death of the accused prior to final judgment terminates his criminal liability and only the civil liability directly arising from and based solely on the offense committed, i.e., civil liability ex delicto in sensa strictiore.”
    2. Corollarily, the claim for civil liability survives notwithstanding the death of accused, if the same may also be predicated on a source of obligation other than delict. Article 1157 of the Civil Code enumerates these other sources of obligation from which the civil liability ‘may arise as a result of the same act or omission:

    a) Law
    b) Contracts
    c) Quasi-contracts
    d) x x x
    e) Quasi-delicts

    1. Where the civil liability survives, as explained in Number 2 above, an action for recovery therefor may be pursued but only by way of filing a separate civil action and subject to Section 1, Rule 111 of the 1985 Rules on Criminal Procedure as amended. This separate civil action may be enforced either against the executor/administrator or the estate of the accused, depending on the source of obligation upon which the same is based as explained above.
    2. Finally, the private offended party need not fear a forfeiture of his right to file this separate civil action by prescription, in cases where during the prosecution of the criminal action and prior to its extinction, the private-offended party instituted together therewith the civil action. In such case, the statute of limitations on the civil liability is deemed interrupted during the pendency of the criminal case, conformably with provisions of Article 1155 of the Civil Code, that should thereby avoid any apprehension on a possible privation of right by prescription.

    Building on this principle, the Court determined that the death of Monroyo extinguished his criminal liability and the civil liability directly arising from the crime. However, it clarified that the victims could still pursue civil claims against his estate based on other legal grounds. The implication is significant: while the state’s pursuit of criminal justice ends with the death of the accused, the victims’ quest for compensation and redress is not necessarily terminated.

    This decision underscores the importance of distinguishing between civil liability ex delicto (arising from the crime itself) and other sources of civil obligation. For instance, if the accused had entered into a contract with the victims that was breached due to his actions, a civil suit for breach of contract could still proceed against his estate. Similarly, if his actions constituted a quasi-delict, such as negligence causing harm, a civil action could be maintained. The Court’s ruling ensures that the victims are not left without recourse simply because the accused has died; they retain the right to seek compensation through alternative legal channels.

    Moreover, the decision reinforces the principle that criminal penalties are personal. They are designed to punish the individual wrongdoer and deter future misconduct. Once the individual is deceased, the purpose of punishment becomes moot. The state’s interest in pursuing criminal justice wanes, and the focus shifts to protecting the rights of the victims through civil remedies. The ruling reflects a balanced approach, acknowledging the finality of death while preserving the victims’ right to seek justice and compensation.

    In summary, the Supreme Court’s decision in People v. Monroyo clarifies the legal consequences of an accused’s death during the pendency of their case. It reaffirms the principle that death extinguishes criminal liability and civil liability arising solely from the crime. However, it also preserves the right of victims to pursue separate civil actions against the deceased’s estate based on other sources of obligation. This nuanced approach ensures that justice is tempered with mercy and that the rights of all parties are considered.

    FAQs

    What happens to the criminal case when the accused dies before final judgment? The criminal case is dismissed because the death of the accused extinguishes criminal liability under Article 89 of the Revised Penal Code.
    What happens to civil liability if the accused dies before final judgment? The civil liability directly arising from the crime (ex delicto) is also extinguished. However, civil claims based on other grounds, like contracts or quasi-delicts, may still be pursued against the deceased’s estate.
    Can the victims still seek compensation after the accused’s death? Yes, victims can file separate civil actions against the estate of the accused based on sources of obligation other than the crime itself, such as contracts or quasi-delicts.
    What is civil liability ex delicto? Civil liability ex delicto refers to the obligation to compensate for damages caused by the commission of a crime. This type of liability is extinguished upon the death of the accused before final judgment.
    What are quasi-delicts? Quasi-delicts are acts or omissions causing damage to another through fault or negligence, where there is no pre-existing contractual relation between the parties. A civil action based on quasi-delict can survive the death of the accused.
    Does the statute of limitations affect the filing of a separate civil action? No, if the civil action was instituted together with the criminal action, the statute of limitations is deemed interrupted during the pendency of the criminal case, according to Article 1155 of the Civil Code.
    What happens to monetary awards if the accused dies before the judgment becomes final? The monetary awards related to the criminal conviction are extinguished. However, similar amounts may be sought in a separate civil action if a valid basis for civil liability exists.
    Can the estate of the accused be held liable for the accused’s actions? Yes, the estate can be held liable for civil obligations arising from sources other than the crime itself, such as contractual breaches or quasi-delicts committed by the accused.

    In conclusion, the Supreme Court’s resolution in People v. Norieto Monroyo y Mahaguay provides a clear framework for understanding the legal consequences of an accused’s death during criminal proceedings. While the death of the accused brings an end to criminal prosecution and extinguishes civil liability directly derived from the crime, it does not necessarily preclude victims from seeking redress through alternative civil actions against the deceased’s estate. The decision underscores the importance of differentiating between criminal and civil liabilities and ensures that the rights of victims are protected even in the face of the accused’s demise.

    For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

    Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
    Source: People of the Philippines vs. Norieto Monroyo y Mahaguay, G.R. No. 223708, October 09, 2019

  • Donation Revocation: Balancing Donor Intent and Donee Compliance

    The Supreme Court has ruled that a single, perceived violation of a donation agreement isn’t always enough to automatically revoke the donation. The Court emphasized the importance of considering whether the violation substantially defeats the purpose of the donation, especially when the donee has generally complied with the main conditions. This decision highlights the need to balance the donor’s intent with the donee’s actions and the overall benefit derived from the donation.

    Landmark Case: Can Leasing Part of Donated Land Void a Teachers’ Association’s Title?

    In Camarines Sur Teachers and Employees Association, Inc. vs. Province of Camarines Sur, the central legal question revolved around whether CASTEA’s act of leasing a portion of a donated property to a third party, Bodega Glassware, constituted a violation significant enough to warrant the automatic revocation of the donation by the Province of Camarines Sur. The Province argued that the lease was an encumbrance, violating the Deed of Donation’s condition. CASTEA contended that the lease was for its benefit, supporting its educational upliftment goals.

    The case originated from a Deed of Donation Inter Vivos executed in 1966, where the Province donated a 600-square-meter parcel of land to CASTEA. The deed stipulated that CASTEA use the land to construct a building for its offices and related associations, prohibiting the sale, mortgage, or encumbrance of the property. In 1995, CASTEA leased a portion of the building to Bodega Glassware. Subsequently, in 2007, the Province revoked the donation, leading to an unlawful detainer case against CASTEA. The Municipal Trial Court in Cities (MTCC) ruled in favor of the Province, ordering CASTEA to vacate the property, which was then overturned by the Regional Trial Court (RTC), which was then challenged before the Court of Appeals.

    The Court of Appeals (CA) sided with the Province, stating that the lease was indeed an encumbrance that violated the donation terms. The CA ordered the reinstatement of the MTCC decision. CASTEA then appealed to the Supreme Court, arguing that the CA erred in reversing the RTC decision and misinterpreted the laws. The Supreme Court faced the task of interpreting the Deed of Donation’s conditions and determining whether the lease agreement constituted a substantial breach justifying revocation. Central to the Court’s analysis was the interpretation of the donation’s terms, balancing the donor’s intentions with the donee’s compliance.

    The Supreme Court, in its decision, emphasized the provisional nature of its ruling on possession, acknowledging that the issue of ownership was inextricably linked but not definitively settled in an unlawful detainer case. Referencing Sections 16 and 18 of Rule 70 of the Rules of Court, the Court underscored that its determination was limited to possession de facto. This approach ensured that the broader issue of ownership could be addressed in a separate, more appropriate action, if necessary. Therefore, while the Court’s analysis touched upon the validity of the donation’s revocation, its ruling focused primarily on who had the immediate right to possess the property.

    The Court then delved into classifying the donation, noting that it was either a modal or onerous one, given the burdens imposed on CASTEA. Drawing from Justice Caguioa’s classifications of donations, the Court highlighted the presence of a prestation: CASTEA’s obligation to construct and use the building for specific purposes. Thus, the donation could not be considered purely gratuitous. This characterization was critical because it determined which legal principles would govern the interpretation of the Deed of Donation. As an onerous or modal donation, the rules governing contracts, as per Articles 732 and 733 of the Civil Code, took precedence. These articles emphasize the importance of contractual stipulations and the parties’ intentions.

    “Donations which are to take effect inter vivos shall be governed by the general provisions on contracts and obligations in all that is not determined in this Title [on Donation]” (Article 732, Civil Code).

    Building on this principle, the Court examined the specific conditions outlined in the Deed of Donation, separating them into positive and negative obligations. CASTEA had to construct a building, a prestation to do. They also had to refrain from selling, mortgaging, or encumbering the property, a prestation not to do. The Court noted that CASTEA had complied with the primary obligation of constructing the building, thus satisfying the main purpose of the donation. The critical issue then became whether the lease agreement, a potential breach of the negative obligation, warranted the donation’s revocation.

    The Supreme Court addressed the validity of the automatic revocation clause, citing its previous ruling in De Luna v. Abrigo. It affirmed that parties could agree to clauses allowing unilateral rescission, similar to automatic revocation in onerous donations. Such clauses are not inherently invalid, provided they adhere to the principles of contract law. However, the Court also emphasized that even with an automatic revocation clause, judicial intervention is necessary to determine the propriety of the revocation, especially when the donee contests it. The need for judicial review ensures fairness and prevents abuse of the revocation power.

    “When a deed of donation, as in this case, expressly provides for automatic revocation and reversion of the property donated, the rules on contract and the general rules on prescription should apply, and not Article 764 of the Civil Code” (Roman Catholic Archbishop of Manila v. CA).

    The Court then analyzed the nature of CASTEA’s breach, considering whether the lease agreement was substantial enough to justify revocation. The Court noted several factors that mitigated the severity of the breach. Firstly, the lease covered only a portion of the building, not the entire property. Secondly, the lease was for a fixed term of 20 years, not a perpetual encumbrance. Thirdly, the rental income was used for the benefit of CASTEA’s members, supporting their welfare and educational goals. These factors indicated that the lease, while technically a violation of the non-encumbrance clause, did not fundamentally undermine the donation’s purpose.

    To further contextualize the breach, the Court invoked Article 1191 of the Civil Code, which addresses the remedy of resolution in reciprocal obligations. Even though donation is typically a unilateral act, the Court reasoned that Article 1191 was relevant in determining the nature of the breach. Quoting Song Fo & Co. v. Hawaiian Philippine Co., the Court reiterated that rescission is warranted only for breaches that are so substantial and fundamental as to defeat the object of the parties in making the agreement. The lease agreement, in this case, did not meet that threshold.

    The Court ultimately concluded that the Province’s revocation of the Deed of Donation was improper and lacked legal basis. While CASTEA had technically violated the non-encumbrance clause, the violation was not substantial enough to defeat the purpose of the donation. The Court, however, ordered CASTEA to pay nominal damages to the Province, equal to one-half of the total rentals received from Bodega Glassware. This award acknowledged CASTEA’s disregard for the Deed of Donation’s provision while recognizing that the breach did not warrant full revocation.

    FAQs

    What was the key issue in this case? The key issue was whether CASTEA’s act of leasing a portion of the donated property to Bodega Glassware constituted a substantial breach of the Deed of Donation, warranting its revocation by the Province. The court had to determine if this single violation was significant enough to void the entire agreement.
    What is a Deed of Donation Inter Vivos? A Deed of Donation Inter Vivos is a legal document where a donor voluntarily transfers property to a donee during the donor’s lifetime. This type of donation takes effect while both parties are alive and is irrevocable unless specific conditions are breached.
    What does ‘encumbrance’ mean in this context? In this context, an encumbrance refers to any burden or claim that affects the use or transfer of the property. The Deed of Donation prohibited CASTEA from encumbering the property, which the Province argued included the lease agreement with Bodega Glassware.
    Why did the Supreme Court award nominal damages? The Supreme Court awarded nominal damages because while the lease agreement violated the non-encumbrance clause, the violation was not substantial enough to justify the revocation of the donation. The damages were meant to acknowledge CASTEA’s technical breach without imposing a harsh penalty.
    What is an automatic revocation clause? An automatic revocation clause is a provision in a contract, including a Deed of Donation, that specifies that the contract will be automatically terminated if certain conditions are not met. The Province argued that CASTEA’s lease agreement triggered the automatic revocation clause in the Deed of Donation.
    What is the difference between modal and onerous donations? A modal donation imposes a prestation or obligation on the donee, such as constructing a building. An onerous donation imposes a burden on the donee that is less than the value of the property donated. In this case, the donation was considered either modal or onerous because CASTEA was required to construct a building on the donated land.
    What legal principles govern onerous donations? Onerous donations are primarily governed by the rules on contracts as outlined in the Civil Code. This means that the courts will consider the intentions of the parties, the terms of the agreement, and whether any breaches are substantial enough to warrant rescission.
    Does this ruling definitively settle the issue of ownership? No, the Supreme Court explicitly stated that its ruling was limited to determining who had a better right to possession of the property. The issue of ownership remains open and can be addressed in a separate legal action.

    This case underscores the importance of carefully drafting donation agreements and understanding the implications of each clause. While automatic revocation clauses can be valid, courts will scrutinize their application to ensure fairness and alignment with the donation’s overall purpose. This decision provides valuable guidance on balancing donor intent and donee compliance in donation disputes.

    For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

    Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
    Source: CAMARINES SUR TEACHERS and EMPLOYEES ASSOCIATION, INC. vs. PROVINCE OF CAMARINES SUR, G.R. No. 199666, October 07, 2019

  • Forged Deeds and the Innocent Purchaser: Protecting Land Ownership in the Philippines

    The Supreme Court’s decision in Spouses Asuncion Malig-Coronel v. Corazon Solis-Quesada clarifies the burden of proof in land disputes involving allegations of forgery and the rights of innocent purchasers for value. The Court ruled that the Spouses Coronel failed to provide clear and convincing evidence of forgery in the deeds transferring ownership, and thus, their claim for reconveyance was denied. This ruling underscores the importance of presenting concrete evidence to challenge the validity of notarized documents and protects the rights of those who acquire property in good faith.

    Unraveling a Land Dispute: Did Forged Signatures Cloud a Property Title?

    The case revolves around a parcel of land originally owned by the Spouses Asuncion and Reynaldo Coronel. They entrusted the property’s care to Asuncion’s aunt, Catalina Hernando. Subsequently, a series of transactions occurred, beginning with a Deed of Donation allegedly transferring the property to Catalina’s granddaughter, Mina Delos Reyes. Delos Reyes then sold the property to Corazon Solis-Quesada. The Spouses Coronel contested these transfers, claiming that the Deed of Donation and the subsequent Deed of Absolute Sale were forgeries. They filed a complaint seeking annulment of the deeds, cancellation of the title, and reconveyance of the property. Quesada, on the other hand, asserted her right as a purchaser in good faith and for value.

    The Regional Trial Court (RTC) granted Quesada’s demurrer to evidence, finding that the Spouses Coronel failed to sufficiently prove their claims. The Court of Appeals (CA) affirmed the RTC’s decision. The central issue before the Supreme Court was whether the Spouses Coronel presented sufficient evidence to warrant the reconveyance of the subject property, considering their allegations of forgery and their claim that Quesada was not an innocent purchaser.

    The Supreme Court began its analysis by reiterating the nature of an action for reconveyance. An action for reconveyance is a legal remedy available to a rightful owner of land that has been wrongfully registered in another person’s name. It aims to transfer the property to its rightful owner. This remedy is often invoked when fraud or error taints the registration process. The Court emphasized that while the decree of registration is respected, the action seeks to correct the wrongful transfer of ownership.

    The Court then addressed the applicable legal framework. Section 53 of Presidential Decree No. 1529, the Land Registration Act, allows an owner to pursue legal and equitable remedies against parties involved in fraudulent registration, provided it does not prejudice the rights of an innocent holder for value. This is further connected to Article 1456 of the Civil Code, which establishes an implied trust when property is acquired through mistake or fraud, obligating the recipient to act as a trustee for the benefit of the person from whom the property came. Together, these provisions provide the basis for actions seeking reconveyance.

    The prescriptive period for such actions is generally ten years from the issuance of the certificate of title, as provided by Article 1144(2) of the Civil Code. However, this prescriptive period does not apply to a party in actual, continuous, and peaceful possession of the property, as their action is considered a suit for quieting of title, which is imprescriptible. An action for reconveyance based on a void contract, such as one lacking consent, is also imprescriptible. This principle acknowledges that void contracts cannot give rise to valid rights, and therefore, the right to challenge them persists indefinitely. The critical question, therefore, becomes the nature of the underlying claim: is it based on implied trust or a void contract?

    In this case, the Spouses Coronel argued that their action was based on void contracts due to forgery, specifically in the Deed of Donation and Deed of Absolute Sale. This placed the burden on them to prove the alleged forgery. The Court emphasized that forgery is not presumed; it must be proven by clear, positive, and convincing evidence. The Spouses Coronel primarily relied on Asuncion’s testimony, asserting that the signatures on the deeds were not genuine. However, the Court found this insufficient.

    The Court cited Cesar v. Sandiganbayan to emphasize the importance of examining both the differences and similarities in questioned signatures. This examination helps determine whether variations are due to forgery or natural variations in a person’s genuine writing. The Spouses Coronel failed to present expert testimony or provide sufficient signature samples for comparison. The Court noted a significant time disparity between the signatures on the questioned deeds (1995 and 2000) and the signatures offered for comparison (2011 and 2013). This temporal gap made it difficult to draw accurate conclusions about the authenticity of the signatures. As the Court stated in Reyes v. Vidal, the closeness in time between the standard signatures and the questioned signatures is critical for an accurate analysis.

    The Court also addressed the Spouses Coronel’s argument that the questioned documents should not be considered public documents due to non-compliance with legal formalities. The Supreme Court emphasized that a notarized document carries a presumption of regularity. To overcome this presumption, clear and convincing evidence is needed. The Spouses Coronel raised this issue only in their motion for reconsideration before the CA, which is procedurally improper. The Court highlighted that issues not raised in the trial court cannot be raised for the first time on appeal, violating the principles of fair play and due process. As such, the Court found no basis to disregard the presumption of regularity attached to the notarized documents.

    Finally, the Court considered whether Quesada qualified as an innocent purchaser for value. This status protects individuals who buy property without notice of any defect in the seller’s title. The burden of proving good faith rests on the purchaser. The Spouses Coronel argued that Quesada’s close relationship with Delos Reyes should have alerted her to potential issues with the title. However, the Court found no concrete evidence to support this claim. Every person dealing with registered land may generally rely on the correctness of the certificate of title. While this rule does not apply when a party has actual knowledge of defects or circumstances that should prompt inquiry, the Spouses Coronel failed to demonstrate that Quesada had such knowledge. The court thus ruled in favor of Quesada by stating that:

    The burden of proving the status of a purchaser in good faith lies upon one who asserts that status, and this onus probandi cannot be discharged by mere invocation of the legal presumption of good faith.

    FAQs

    What was the key issue in this case? The key issue was whether the Spouses Coronel provided sufficient evidence to prove forgery and invalidate the transfer of land ownership to Corazon Solis-Quesada. The court assessed the validity of the documents and the status of Quesada as an innocent purchaser for value.
    What is an action for reconveyance? An action for reconveyance is a legal remedy to transfer land wrongfully registered in another person’s name to its rightful owner. It is often based on fraud or error in the registration process, aiming to correct the wrongful transfer of ownership.
    What is the prescriptive period for an action for reconveyance based on fraud? Generally, the prescriptive period is ten years from the issuance of the certificate of title. However, this does not apply to a party in actual possession or when the action is based on a void contract.
    What is required to prove forgery in a legal document? Forgery must be proven by clear, positive, and convincing evidence. This often requires expert testimony or a comparison of signatures made at a similar time to the questioned document.
    What is the significance of a notarized document? A notarized document is considered a public document and enjoys a presumption of regularity. This means it is presumed to be valid and duly executed unless proven otherwise by clear and convincing evidence.
    What is an innocent purchaser for value? An innocent purchaser for value is someone who buys property without notice of any defect in the seller’s title and pays a fair price. They are protected under the law, even if the seller’s title is later found to be defective.
    What is the burden of proof for claiming to be an innocent purchaser? The burden of proof lies on the person claiming to be an innocent purchaser to demonstrate they bought the property in good faith and without knowledge of any adverse claims. Mere invocation of good faith is not enough.
    Why was the timing of signature samples important in this case? The timing was crucial because the court emphasized that signature samples used for comparison should be from a period close to when the questioned document was signed. This ensures a more accurate analysis, considering that signatures can change over time due to age or health.

    In conclusion, the Supreme Court’s decision reinforces the importance of providing concrete evidence when challenging the validity of notarized documents and claiming ownership of land. It protects the rights of innocent purchasers who rely on the correctness of certificates of title. The case serves as a reminder to meticulously gather and present evidence, particularly in cases involving allegations of forgery.

    For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

    Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
    Source: Spouses Asuncion Malig-Coronel and Reynaldo Coronel vs. Corazon Solis-Quesada, G.R. No. 237465, October 07, 2019

  • Forged Signatures and Land Titles: Safeguarding Property Rights in the Philippines

    In Spouses Asuncion Malig-Coronel and Reynaldo Coronel v. Corazon Solis-Quesada, the Supreme Court addressed the complexities of land ownership disputes involving allegations of forged documents. The Court reiterated that forgery must be proven with clear and convincing evidence, and that a notarized document carries a presumption of regularity that can only be overturned by strong proof. This decision underscores the importance of due diligence in property transactions and the protection afforded to innocent purchasers for value.

    Land Dispute: Can a Forged Deed Undermine a Property Title?

    The case revolves around a complaint filed by Spouses Coronel seeking the annulment of deeds, cancellation of TCT No. 335024, recovery of possession, reconveyance, and damages against Corazon Solis-Quesada. The spouses claimed ownership of a property in Tarlac City, which they had entrusted to Asuncion’s aunt, Catalina Hernando, for safekeeping. However, a series of transactions, including a Deed of Donation to Catalina’s granddaughter, Mina Delos Reyes, and a subsequent Deed of Absolute Sale to Quesada, led to the property being registered under Quesada’s name. The Coronels alleged that these transactions were based on forged documents, specifically the Deed of Donation and the Deed of Absolute Sale.

    Quesada countered that she was a purchaser in good faith and for value, relying on the validity of the documents presented. The RTC granted Quesada’s demurrer to evidence, finding that the Coronels failed to sufficiently prove their case, and the Court of Appeals affirmed this decision. The central issue before the Supreme Court was whether the evidence presented by the Coronels was sufficient to warrant the reconveyance of the property based on the alleged forgery and fraud.

    The Supreme Court began its analysis by emphasizing the nature of a demurrer to evidence. It reiterated that a demurrer challenges the sufficiency of the plaintiff’s evidence to sustain a verdict. The Court framed the key question: Did the Spouses Coronel present enough competent proof before the trial court to support their claim and warrant a favorable judgment?

    The Court clarified the remedy of reconveyance, defining it as a legal and equitable action granted to the rightful owner of land that has been wrongfully registered in another’s name. Reconveyance aims to transfer the property to its rightful owner, respecting the decree of registration as incontrovertible. The Court then cited the relevant legal provisions that govern actions for reconveyance:

    In all cases of registration procured by fraud, the owner may pursue all his legal and equitable remedies against the parties to such fraud without prejudice, however, to the rights of any innocent holder for value of a certificate of title. After the entry of the decree of registration on the original petition or application, any subsequent registration procured by the presentation of a forged duplicate certificate of title, or a forged deed or other instrument, shall be null and void.

    This provision, stemming from Presidential Decree No. 1529, is further connected to Article 1456 of the Civil Code, establishing an implied trust for the benefit of the person from whom the property was fraudulently obtained. The Court emphasized that the prescriptive period for reconveyance of fraudulently registered property is ten years from the issuance of the certificate of title, as per Article 1144(2) of the Civil Code. However, this prescriptive period does not apply to parties in actual possession seeking reconveyance based on implied trust, as their action is akin to a suit for quieting of title, which is imprescriptible. Similarly, actions based on void contracts are also imprescriptible.

    The Supreme Court found that the Coronels’ action was based on a claim of void contracts due to the alleged forgery of the Deed of Donation and Deed of Absolute Sale. Therefore, the pivotal question was whether the signatures on these documents were indeed forged, rendering the documents void. The Court pointed out that the lower courts found the evidence of forgery insufficient. Citing previous jurisprudence, the Court stated the burden of proof lies on the party alleging forgery, and it must be proven by clear, positive, and convincing evidence.

    To support their claim of forgery, the Spouses Coronel presented Asuncion’s judicial affidavit and testimony, where she denied the authenticity of her and her husband’s signatures on the Deed of Donation, and alleged that Rodrigo, Delos Reyes’ husband, was in Hawaii at the time of the Deed of Absolute Sale. The Court, however, emphasized that a proper examination to determine forgery should involve a careful analysis of both the differences and similarities in the questioned signatures, stating:

    There are two main questions, or difficulties, that confront the examiner of an alleged forgery. The first of these is to determine how much and to what extent genuine writing will diverge from a certain type, and the second is how and to what extent will a more or less skillful forgery be likely to succeed and be likely to fail in embodying the essential characteristics of a genuine writing.

    The Court found that the Coronels failed to conduct an adequate examination of the signatures. They did not present an expert witness or provide sufficient samples of their genuine signatures from the relevant time period for comparison. Instead, they relied on their own denials and comparisons with signatures on pleadings filed much later.

    The Court cited Reyes v. Vidal, emphasizing the importance of using signature standards that are close in time to the questioned signatures. Signatures can change over time due to age and health, making comparisons with recent signatures unreliable. Thus, the Court rejected the Coronels’ argument that the trial court should have compared the signatures on the questioned documents with their signatures on the pleadings.

    The Court also addressed the Coronels’ claim that the questioned documents were not public documents due to non-compliance with legal formalities. It reiterated that a notarized document enjoys a presumption of regularity and is prima facie evidence of the truth of the facts stated therein. The burden of proof to overcome this presumption lies with the party contesting the document.

    Turning to the issue of whether Quesada was an innocent purchaser for value, the Court emphasized that the burden of proving bad faith lies on the party asserting it. A purchaser in good faith is one who buys property without notice that another person has a right or interest in the property and pays a fair price before receiving such notice. While every person dealing with registered land can rely on the correctness of the certificate of title, this rule does not apply when the party has actual knowledge of facts that should prompt further inquiry.

    The Coronels argued that Quesada’s close relationship with Delos Reyes should have put her on notice of the defect in Delos Reyes’ title. However, the Court found no evidence that Quesada was aware of any circumstances surrounding the property or that the certificate of title revealed any other claims. The Coronels’ allegation of collusion was deemed speculative.

    Finally, the Court addressed the Coronels’ claim that their action had not prescribed because they were in possession of the property. However, the evidence presented indicated that Delos Reyes and her family had occupied the property, and the tenant installed by the Coronels only knew of them as owners of the lot at the back. The Court reiterated that each party must prove their affirmative allegations, and the Coronels’ evidence failed to establish their continuous and peaceful possession of the property.

    In conclusion, the Supreme Court found that the Coronels failed to prove forgery, Quesada’s knowledge of any defect in Delos Reyes’ title, or their continuous possession of the property. Therefore, the Court affirmed the CA’s decision to dismiss the complaint, upholding the principle that clear and convincing evidence is required to overturn the presumption of regularity of notarized documents and establish fraud in property transactions.

    FAQs

    What was the key issue in this case? The key issue was whether the Spouses Coronel presented sufficient evidence to warrant the reconveyance of a property registered under Corazon Solis-Quesada’s name, based on allegations of forgery and fraud in the underlying property transfers.
    What is an action for reconveyance? An action for reconveyance is a legal remedy sought by the rightful owner of land that has been wrongfully registered in another person’s name, aiming to compel the latter to transfer the land back to the rightful owner.
    What is the prescriptive period for an action for reconveyance based on fraud? The prescriptive period for an action for reconveyance based on fraud is generally ten years from the date of the issuance of the certificate of title. However, this period does not apply if the person seeking reconveyance is in actual possession of the property.
    What is required to prove forgery in a legal document? Forgery must be proven by clear, positive, and convincing evidence. This typically involves a comparison of the questioned signatures with genuine signatures from the relevant time period, often with the assistance of an expert witness.
    What is the legal effect of a notarized document? A notarized document is considered a public document and enjoys a presumption of regularity. This means it is presumed to be authentic and to have been executed voluntarily, unless proven otherwise by clear and convincing evidence.
    What is an innocent purchaser for value? An innocent purchaser for value is someone who buys property without notice that another person has a right to or interest in the property and pays a fair price before receiving such notice.
    What is the duty of a purchaser of registered land? Generally, a purchaser of registered land can rely on the correctness of the certificate of title. However, if the purchaser has knowledge of facts that should prompt further inquiry, they have a duty to investigate potential defects in the title.
    What evidence did the Spouses Coronel present to support their claim of forgery? The Spouses Coronel primarily presented Asuncion’s judicial affidavit and testimony, where she denied the authenticity of her and her husband’s signatures on the Deed of Donation. They also alleged that Rodrigo was out of the country when the Deed of Absolute Sale was executed.
    Why did the Supreme Court reject the Spouses Coronel’s claim of forgery? The Supreme Court found that the Spouses Coronel failed to present sufficient evidence to prove forgery. They did not provide an expert witness, nor did they provide sufficient signature samples from the relevant time period for comparison.

    The Supreme Court’s decision underscores the importance of presenting concrete and compelling evidence when alleging forgery or fraud in property transactions. It highlights the protection afforded to innocent purchasers for value and the need for diligence in safeguarding property rights. This ruling reinforces the stability of the Torrens system and the reliance placed on registered land titles.

    For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

    Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
    Source: SPOUSES ASUNCION MALIG-CORONEL AND REYNALDO CORONEL, VS. CORAZON SOLIS-QUESADA, G.R. No. 237465, October 07, 2019

  • Jurisdictional Thresholds: Assessed Value vs. Market Value in Property Disputes

    The Supreme Court has clarified that in actions involving title to real property, the Regional Trial Court’s (RTC) jurisdiction hinges on the property’s assessed value, not its market value, as stated in the complaint. This means if a plaintiff fails to properly indicate the assessed value of the property in their complaint, the RTC may lack the authority to hear the case, potentially leading to its dismissal. This ruling reinforces the principle that jurisdiction is determined by law and the specific allegations in the complaint.

    Land Dispute Limbo: When a Missing Assessed Value Undermines a Property Claim

    This case revolves around Genoveva G. Gabrillo’s claim to a parcel of land in Davao City, which she asserted through a Transfer of Rights from Ernesto A. Cadiente, Sr. Gabrillo filed a case against the heirs of Olimpio Pastor seeking reconveyance and annulment of title after the respondents obtained a free patent over the land. However, the legal battle took an unexpected turn when the RTC dismissed the case, citing a lack of jurisdiction due to Gabrillo’s failure to state the assessed value of the property in her complaint. The central legal question is whether the RTC acquired jurisdiction based on the stated market value of the property, or if the omission of the assessed value was a fatal flaw. This decision highlights the critical importance of correctly pleading jurisdictional facts in property disputes.

    The Supreme Court emphasized the fundamental rule that jurisdiction over the subject matter is conferred by law and determined by the allegations in the complaint. Specifically, in actions involving title to real property, jurisdiction rests on the assessed value of the property, not its market value. The assessed value is the valuation ascribed to the property by taxing authorities for determining the applicable tax rate. The court referenced Section 19(2) of B.P. Blg. 129, as amended by R.A. No. 7691, which clearly stipulates that RTCs have exclusive original jurisdiction over civil actions involving title to real property where the assessed value exceeds Twenty Thousand Pesos (₱20,000.00), or Fifty Thousand Pesos (₱50,000.00) in Metro Manila.

    SEC. 19.Jurisdiction in civil cases. — The Regional Trial Courts shall exercise exclusive original jurisdiction:

    x x x x

    (2) In all civil actions which involve the title to, or possession of, real property, or any interest therein, where the assessed value of the property involved exceeds Twenty [T]housand [P]esos ([P]20,000.00) or for civil actions in Metro Manila, where such value exceeds Fifty thousand pesos ([P]50,000.00) except actions for forcible entry into and unlawful detainer of lands or buildings, original jurisdiction over which is conferred upon the Metropolitan Trial Courts, Municipal Trial Courts, and Municipal Circuit Trial Courts[.]

    The Court contrasted assessed value with fair market value, explaining that assessed value is a fraction of the realty’s fair market value, calculated by multiplying the market value by the assessment level. While fair market value represents the price a willing buyer and seller would agree upon, assessed value is the taxable value used by local assessors. The Court emphasized that B.P. Blg. 129 explicitly requires the assessed value, not the market value, to determine jurisdiction. The failure to allege the assessed value in the complaint is a critical omission that prevents the court from ascertaining whether it has jurisdiction over the action.

    The Supreme Court acknowledged a previous exception in Foronda-Crystal v. Son, where the failure to allege the assessed value was not fatal because the assessed value could be found in documents annexed to the complaint. However, in this case, Gabrillo’s complaint did not include any documents reflecting the assessed value of the property. The Court noted that attaching the sworn declaration of real property, which bears the assessed value, could have triggered the liberal application of the rule, as tax declarations enjoy a presumption of regularity. Since the complaint lacked this crucial information, the RTC was justified in dismissing the case for lack of jurisdiction. Moreover, the court emphasized that the lawmakers intentionally specified assessed value in R.A. No. 7691, and a decision to consider market value would require legislative action. Therefore, the assessed value remains the sole determinant of jurisdiction in real actions.

    FAQs

    What was the key issue in this case? The key issue was whether the Regional Trial Court (RTC) acquired jurisdiction over a property dispute when the complaint stated the market value but not the assessed value of the property.
    What is assessed value? Assessed value is the value assigned to a property by taxing authorities for the purpose of calculating property taxes. It is usually a fraction of the property’s fair market value.
    What is fair market value? Fair market value is the price a willing buyer would pay a willing seller for a property in an open market. It reflects what the property could realistically sell for.
    Why is assessed value important for jurisdiction? Philippine law specifies that the assessed value of a property determines which court (Municipal Trial Court or Regional Trial Court) has jurisdiction over cases involving title to or possession of real property.
    What happens if the assessed value is not stated in the complaint? If the assessed value is not stated in the complaint, the court may not be able to determine whether it has jurisdiction, potentially leading to the dismissal of the case.
    Can a court take judicial notice of the assessed value? No, courts cannot take judicial notice of the assessed value. It must be specifically alleged in the complaint or included in attached documents.
    Is there an exception to the rule about assessed value? Yes, if the assessed value is not stated in the complaint but can be found in documents attached to the complaint, the court may consider it.
    What was the Supreme Court’s ruling in this case? The Supreme Court ruled that the RTC did not have jurisdiction because the complaint failed to allege the assessed value of the property, and no attached documents provided this information.

    This case underscores the importance of meticulously adhering to procedural requirements when initiating legal actions, particularly those involving real property. Failing to properly plead jurisdictional facts, such as the assessed value of the property, can have significant consequences, including the dismissal of the case. Therefore, plaintiffs and their legal counsel must ensure that all necessary information is accurately and completely presented in the complaint.

    For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

    Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
    Source: Genoveva G. Gabrillo v. Heirs of Olimpio Pastor, G.R. No. 234255, October 02, 2019

  • Motion for Reconsideration: Suspending Execution and Due Process in Land Disputes

    The Supreme Court held that a writ of execution cannot be issued against parties whose motion for reconsideration is still pending before the Court of Appeals (CA). The CA erred in believing that the Supreme Court’s decision in G.R. No. 175375, which involved a different party, was binding on the petitioners, who were not parties in that case and whose motion for reconsideration was unresolved. This ruling underscores the importance of due process and the right to appeal in land disputes.

    Unresolved Appeals: When Can a Land Ownership Ruling Be Enforced?

    This case revolves around a protracted dispute over land ownership, specifically concerning Lot No. 3050 in San Mateo, Rizal. The petitioners, Simeona Prescilla, Gloria Prescilla, et al., claimed ownership based on their long-term possession and cultivation since 1940. However, respondents Conrado Lasquite and Juanito Andrade obtained Original Certificates of Title (OCTs) for the same property, leading to a legal battle that spanned decades and multiple appeals.

    The Regional Trial Court (RTC) initially ruled in favor of Lasquite and Andrade regarding Lot No. 3050. On appeal, the Court of Appeals (CA), Eighth Division, reversed the RTC’s decision and declared Victory Hills, Inc. as the absolute owner of the land. The Prescillas filed a Motion for Reconsideration. Meanwhile, Lasquite and Andrade directly filed a Petition for Review on Certiorari with the Supreme Court, docketed as G.R. No. 175375.

    The CA then suspended the resolution of the Prescillas’ Motion for Reconsideration pending the Supreme Court’s decision. Eventually, the Supreme Court reversed the CA’s decision in G.R. No. 175375, reinstating the RTC’s ruling in favor of Lasquite and Andrade, but the Prescillas were not parties in the appeal before the Supreme Court. Following this, Lasquite and Andrade sought a writ of execution from the RTC, which was granted. The Prescillas challenged this through a Petition for Certiorari, arguing that their Motion for Reconsideration was still pending before the CA.

    The heart of the Supreme Court’s decision lies in the principle of due process and the effect of a pending Motion for Reconsideration. The Court emphasized that a judgment is conclusive only upon the parties involved and their successors-in-interest. The Court cited Guy v. Atty. Gacott:

    A decision rendered on a complaint in a civil action or proceeding does not bind or prejudice a person not impleaded therein, for no person shall be adversely affected by the outcome of a civil action or proceeding in which he is not a party. The principle that a person cannot be prejudiced by a ruling rendered in an action or proceeding in which he has not been made a party conforms to the constitutional guarantee of due process of law.

    The Supreme Court also referred to Section 4, Rule 52 of the Rules of Court:

    Section 4, Rule 52 of the Rules of Court is clear and unequivocal: the pendency of a motion for reconsideration filed on time and by the proper party shall stay the execution of the judgment or final resolution sought to be reconsidered.

    The Court found that the CA, Seventh Division, erred in upholding the writ of execution against the Prescillas because their Motion for Reconsideration was still pending before the CA, Eighth Division. The Supreme Court’s decision in G.R. No. 175375 only addressed the rights of Victory Hills, Inc. and did not resolve the ownership claims between the Prescillas and Lasquite and Andrade. Because the Prescillas were not parties to G.R. No. 175375, the ruling in that case could not bind them.

    The Court clarified that the doctrine established in Suson v. Court of Appeals did not apply. In Suson, a party was bound by a judgment even though they were not impleaded because they had the opportunity to intervene but failed to do so. However, the Prescillas’ situation was different; their Motion for Reconsideration was pending, and therefore, any attempt to intervene in G.R. No. 175375 would have been considered forum shopping.

    The Supreme Court also criticized the CA, Eighth Division, for suspending the resolution of the Prescillas’ Motion for Reconsideration pending the outcome of G.R. No. 175375. The Court underscored that this action effectively prevented the Prescillas from exercising their right to appeal, leading to a denial of due process. The delay caused by the unresolved Motion for Reconsideration frustrated the objective of the rules of procedure, which is to ensure a just, speedy, and inexpensive resolution of cases.

    The implications of this decision are significant. It reinforces the principle that a pending Motion for Reconsideration suspends the execution of a judgment against the party who filed the motion. Moreover, it emphasizes that a decision of the Supreme Court only binds the parties involved in that particular case and does not prejudice the rights of other claimants who were not part of the proceedings. This ensures that all parties have a fair opportunity to litigate their claims fully and to exercise their right to appeal.

    FAQs

    What was the key issue in this case? The central issue was whether a writ of execution could be issued against parties whose Motion for Reconsideration was still pending before the Court of Appeals. The Supreme Court determined that it could not.
    Who were the parties involved? The petitioners were the Prescilla family, who claimed ownership of the land based on long-term possession. The respondents were Lasquite and Andrade, who obtained Original Certificates of Title for the same property.
    What was the significance of the Motion for Reconsideration? The pending Motion for Reconsideration filed by the Prescillas had the effect of suspending the execution of the judgment against them, as per Rule 52 of the Rules of Court. This meant that the ruling was not yet final and could not be enforced against them.
    Why was the Supreme Court’s decision in G.R. No. 175375 not binding on the Prescillas? The Prescillas were not parties to the case in G.R. No. 175375; that case was between Lasquite and Andrade and Victory Hills, Inc. As such, the ruling in that case could not affect the rights of the Prescillas, who had not had an opportunity to present their case before the Supreme Court.
    What did the Court say about the CA’s decision to suspend the Prescillas’ Motion for Reconsideration? The Supreme Court criticized the Court of Appeals for suspending the resolution of the Prescillas’ Motion for Reconsideration, deeming that this action effectively prevented the Prescillas from exercising their right to appeal, leading to a denial of due process.
    What is the principle of due process in this context? Due process requires that all parties have a fair opportunity to litigate their claims fully and to exercise their right to appeal. In this case, the Prescillas were denied due process because the CA suspended the resolution of their Motion for Reconsideration.
    What is the doctrine established in Suson v. Court of Appeals, and why was it inapplicable here? In Suson v. Court of Appeals, a party was bound by a judgment even though they were not impleaded because they had the opportunity to intervene but failed to do so. Here, the Prescillas could not intervene in G.R. No. 175375 because their Motion for Reconsideration was pending.
    What was the effect of the Supreme Court’s decision in this case? The Supreme Court reversed the Court of Appeals’ decision and vacated the orders of the Regional Trial Court, which had granted the writ of execution against the Prescillas. The case was remanded to the Court of Appeals for resolution of the pending Motion for Reconsideration.

    This case serves as a reminder of the importance of adhering to procedural rules and safeguarding the right to due process in legal proceedings. The Supreme Court’s decision underscores the principle that a judgment can only be enforced against parties who have had a full and fair opportunity to litigate their claims. The failure to resolve a pending Motion for Reconsideration can have significant implications, potentially leading to a denial of justice.

    For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

    Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
    Source: SIMEONA, GLORIA AND RODOLFO (ALL SURNAMED PRESCILLA) v. CONRADO O. LASQUITE, G.R. No. 205805, September 25, 2019

  • Registered Vehicle Owner’s Liability: Clarifying Responsibility in Motor Vehicle Accidents

    The Supreme Court has affirmed that the registered owner of a vehicle bears primary responsibility for damages resulting from its operation, regardless of who the actual owner or driver may be. This ruling underscores the importance of vehicle registration in assigning liability in accident cases, ensuring that victims have a clear path to seek compensation. The decision clarifies the application of the registered owner rule and its implications for both the public and the actual parties involved in motor vehicle accidents, while acknowledging avenues for recourse and indemnification between the registered and actual owners.

    Behind the Wheel: Who Pays When Accidents Happen?

    This case, Spouses Emilio Mangaron, Jr. and Erlinda Mangaron vs. Hanna Via Design & Construction, revolves around a vehicular accident where the petitioners sustained serious injuries. The petitioners sought damages from Hanna Via Design & Construction (respondent), alleging vicarious liability for the negligent driving of Crestino T. Bosquit, who was driving a truck that collided with their vehicle. A central issue emerged: the truck was registered under the name of Power Supply and Equipment Parts, not Hanna Via Design & Construction. This raised questions about who should bear the responsibility for the accident and the resulting damages.

    At the heart of this case lies the application of the **registered owner rule**, a well-established principle in Philippine jurisprudence. This rule dictates that the registered owner of a motor vehicle is primarily responsible for the consequences of its operation, especially concerning the public and third parties. The purpose of this rule is to easily identify and hold accountable those responsible for damages or injuries caused by vehicles on public roads. The registration requirement ensures that there is a definite individual or entity to pursue in case of accidents, simplifying the process of seeking compensation.

    The Regional Trial Court (RTC) initially denied the respondent’s demurrer to evidence, maintaining its jurisdiction over the case. However, the Court of Appeals (CA) reversed this decision, finding that the RTC committed grave abuse of discretion by failing to consider the registered owner rule. The CA emphasized that since Power Supply was the registered owner of the truck, they should be held liable, not Hanna Via Design & Construction. The Supreme Court agreed with the CA’s assessment, reinforcing the significance of vehicle registration in determining liability.

    The Supreme Court underscored the importance of the registered owner rule, quoting Metro Manila Transit Corporation v. Cuevas, 759 Phil. 286, 292-293 (2015):

    Registration is required not to make said registration the operative act by which ownership in vehicles is transferred, as in land registration cases, because the administrative proceeding of registration does not bear any essential relation to the contract of sale between the parties, but to permit the use and operation of the vehicle upon any public highway (section 5 [a], Act No. 3992, as amended.) The main aim of motor vehicle registration is to identify the owner so that if any accident happens, or that any damage or injury is caused by the vehicle on the public highways, responsibility therefore can be fixed on a definite individual, the registered owner. Instances are numerous where vehicles running on public highways caused accidents or injuries to pedestrians or other vehicles without positive identification of the owner or drivers, or with very scant means of identification. It is to forestall these circumstances, so inconvenient or prejudicial to the public, that the motor vehicle registration is primarily ordained, in the interest of the determination of persons responsible for damages or injuries caused on public highways.

    The Court clarified that the law aims to prevent the evasion of liability and ensure that victims of vehicular accidents can be properly compensated. By assigning liability to the registered owner, the process of seeking redress is streamlined, and the public is protected from the potential difficulties of identifying the responsible party. This does not, however, mean that the actual owner is entirely shielded from liability. The principle of unjust enrichment comes into play, allowing the registered owner to seek indemnification from the actual owner or employer of the negligent driver. This ensures fairness and prevents unjust outcomes.

    Building on this principle, the Court acknowledged that while the registered owner is primarily liable to the public, there are avenues for recourse against the actual owner. The registered owner can pursue a cross-claim against the actual employer of the negligent driver to recover any damages they were compelled to pay. This balances the need to protect the public with the principle that the party ultimately responsible for the negligence should bear the financial burden. This approach ensures that the rights of all parties are preserved while upholding the public policy behind the registered owner rule.

    FAQs

    What is the registered owner rule? The registered owner rule states that the registered owner of a motor vehicle is primarily responsible for the consequences of its operation, especially concerning the public and third parties. This rule is in place to easily identify and hold accountable those responsible for damages or injuries caused by vehicles on public roads.
    Who was the registered owner of the vehicle in this case? In this case, the registered owner of the Isuzu truck involved in the accident was Power Supply and Equipment Parts, not Hanna Via Design & Construction. This was a key factor in the court’s decision regarding liability.
    Why did the Court of Appeals reverse the RTC’s decision? The Court of Appeals reversed the RTC’s decision because the RTC failed to adequately consider the registered owner rule. The CA found that the RTC committed grave abuse of discretion by not recognizing that Power Supply, as the registered owner, should be held primarily liable.
    Can the registered owner seek reimbursement from the actual owner? Yes, the registered owner who is held liable for damages can seek indemnification from the actual owner or the employer of the negligent driver. This is based on the principle of unjust enrichment, ensuring that the party ultimately responsible bears the financial burden.
    What is a demurrer to evidence? A demurrer to evidence is an objection by one party in a legal action, asserting that the evidence presented by the opposing party is insufficient to prove their case. If a court grants a demurrer to evidence, it effectively dismisses the case.
    What was the basis for the petitioners’ claim against Hanna Via Design & Construction? The petitioners sought to hold Hanna Via Design & Construction vicariously liable for the negligent driving of Crestino T. Bosquit, who they claimed was an employee of the company. They argued that the company should be responsible for the damages caused by its employee’s negligence.
    What is the significance of vehicle registration? Vehicle registration is crucial for identifying the owner of a vehicle so that responsibility can be fixed in case of accidents or damages. It ensures that there is a definite individual or entity to pursue for compensation, protecting the public and streamlining the legal process.
    What is the impact of this ruling on victims of vehicular accidents? This ruling clarifies who is primarily liable in case of an accident, making it easier for victims to seek compensation. By reinforcing the registered owner rule, the court ensures that victims have a clear path to pursue damages from a readily identifiable party.

    In conclusion, the Supreme Court’s decision in this case reaffirms the importance of the registered owner rule in Philippine law. While the registered owner is held primarily liable for damages resulting from the operation of a vehicle, the law allows for recourse against the actual owner or employer of a negligent driver, ensuring a fair and just outcome for all parties involved. The ruling provides clarity and guidance for future cases involving motor vehicle accidents and liability.

    For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

    Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
    Source: SPOUSES EMILIO MANGARON, JR. AND ERLINDA MANGARON, VS. HANNA VIA DESIGN & CONSTRUCTION, G.R. No. 224186, September 23, 2019