G.R. No. 152132 ; July 24, 2007
LORDITO ARROGANTE, JOHNSTON ARROGANTE, ARME ARROGANTE, and FE D. ARROGANTE, Petitioners, vs. BEETHOVEN DELIARTE, Joined by SPOUSE LEONORA DUENAS, Respondents.

FACTS

The lot in controversy was originally the conjugal property of spouses Bernabe Deliarte, Sr. and Gregoria Placencia. They had nine children, including respondent Beethoven Deliarte and petitioner Fe Deliarte Arrogante. After a series of family tragedies where Beethoven shouldered substantial hospitalization and burial expenses, the Deliarte siblings, including Fe, executed a private deed of absolute sale on November 16, 1978. They waived and conveyed all their rights, interests, and claims over the lot to Beethoven for a consideration of ₱15,000.00. Beethoven thereafter possessed the lot openly and as owner. On March 26, 1986, all siblings except Fe signed a deed confirming the 1978 sale.
In 1993, petitioner Lordito Arrogante, Fe’s son, installed placards on the lot’s fence, publicly accusing Beethoven of being a land grabber who had destroyed their grandfather’s will. This prompted Beethoven and his wife to file an action for quieting of title and damages. Petitioners argued that the 1978 sale could not have conveyed the entire lot, as their father Bernabe was still alive at that time and did not sign the document. They contended the siblings could only sell their prospective shares from their mother’s half of the conjugal property, leaving Fe with a share from their father’s half.

ISSUE

The primary issues were: (1) the validity of the 1978 sale as a conveyance of the entire lot; (2) the applicability of the parol evidence rule and the Statute of Frauds; and (3) the propriety of holding petitioners jointly and severally liable for moral damages.

RULING

The Supreme Court affirmed the Court of Appeals’ decision, upholding the validity of the sale and the award of moral damages. On the first issue, the Court ruled that the 1978 deed was a valid conveyance of the entire lot. The siblings, as compulsory heirs, had a vested right to their hereditary portions upon the death of their mother Gregoria in 1978. This vested right constituted an actionable property interest they could legally alienate. The consideration was not limited to the stated ₱15,000; parol evidence was properly admitted to show the additional consideration of Beethoven’s payment of significant family expenses, which the parties intended to compensate. The sale was completely executed and partly performed, taking it out of the Statute of Frauds.
Regarding moral damages, the Court found petitioners jointly and severally liable. The defamatory placards, erected by Lordito, caused Beethoven humiliation given his professional standing. The other petitioners, by their failure to disavow Lordito’s acts or remove the placards despite knowledge, acquiesced and participated in the injury. Their collective inaction, coupled with their shared interest in disputing Beethoven’s title, established their solidarity in causing the besmirching of his reputation, justifying solidary liability for the resulting moral damages.