GR 214319; (November, 2020) (Digest)
G.R. No. 214319 , November 04, 2020
MYRNA C. PASCO, PETITIONER, VS. ISABEL CUENCA, ROMEO M. YTANG, JR., AND ESTHER C. YTANG, RESPONDENTS.
FACTS
Petitioner Myrna Pasco filed a complaint for annulment of title and recovery of ownership over a parcel of land. She alleged that in 1986, the registered owners, Spouses Antonio Baguispas and Isabel Cuenca, sold the property to her via a notarized Deed of Sale. After Antonio’s death, Isabel executed an affidavit of self-adjudication over the lot and subsequently sold it to respondents Spouses Ytang in 1998, who then obtained a new title. Pasco sought to nullify these subsequent transactions and affirm her ownership.
Respondents contended the 1986 sale was fictitious and simulated, executed only to serve as collateral for Pasco’s loan application with the Social Security System. They argued there was no actual consideration paid, and Pasco never asserted ownership over the property for over a decade. The Regional Trial Court ruled in favor of Pasco, declaring her the lawful owner. The Court of Appeals reversed, holding the 1986 deed void for lack of consideration and simulation.
ISSUE
Whether the Court of Appeals erred in declaring the 1986 Deed of Sale between the Spouses Baguispas and petitioner void for lack of consideration and simulation.
RULING
The Supreme Court denied the petition and affirmed the CA Decision. The legal logic rests on the principle that a contract of sale requires a certain price in money as its essential element. Under Article 1471 of the Civil Code, if the price is simulated, the sale is void. The Court found the circumstances surrounding the 1986 transaction indicative of simulation. Crucially, Pasco failed to present any credible proof of payment of the purported purchase price. Her claim of paying in cash was unsupported by receipts or other corroborating evidence.
Furthermore, her conduct after the alleged sale was inconsistent with ownership. For thirteen years, she did not take possession of the property, pay real estate taxes, or seek to register the deed and transfer the title to her name. This prolonged inaction is a clear badge of simulation, demonstrating the parties had no real intention to be bound by a true sale. Consequently, the simulated 1986 sale being void, Isabel retained ownership and had the capacity to validly convey the property to the Spouses Ytang in 1998. The subsequent sale was therefore upheld.