GR 176014; (September, 2009) (Digest)
G.R. No. 176014; September 17, 2009
ALICE VITANGCOL and NORBERTO VITANGCOL, Petitioners, vs. NEW VISTA PROPERTIES, INC., MARIA ALIPIT, REGISTER OF DEEDS OF CALAMBA, LAGUNA, and the HONORABLE COURT OF APPEALS, Respondents.
FACTS
The controversy involves Lot No. 1702, covered by TCT No. (25311) 2528 in the names of spouses Clemente and Maria Alipit. On June 18, 1989, the Alipits executed a Special Power of Attorney (SPA) authorizing Milagros de Guzman to sell a property described therein as “Lot No. 1735.” Pursuant to this SPA, De Guzman executed a Deed of Absolute Sale on August 9, 1989, in favor of respondent New Vista Properties, Inc. However, the deed described the sold property as “Lot No. 1702,” which New Vista subsequently occupied, fenced, and paid taxes for. Over a decade later, in August 2001, petitioner Vitangcol purchased the same Lot No. 1702 directly from Maria Alipit, leading to the cancellation of the original title and the issuance of a new one in Vitangcol’s name. New Vista then filed a complaint for quieting of title against Vitangcol and Alipit.
ISSUE
Whether the Court of Appeals erred in reversing the trial court’s dismissal of the complaint for quieting of title, which was grounded on the failure to attach the SPA to the amended complaint and the perceived unenforceability of the sale under the Statute of Frauds.
RULING
The Supreme Court denied the petition and affirmed the Court of Appeals’ ruling. The legal logic centers on the proper determination of a cause of action in a motion to dismiss and the doctrine of equitable estoppel. The trial court erroneously dismissed the amended complaint based solely on New Vista’s failure to attach the SPA, treating it as a failure to state a cause of action. A cause of action exists if the pleading alleges facts which, if true, would establish the plaintiff’s right to the relief demanded. New Vista’s amended complaint sufficiently alleged its prior purchase, payment, possession, and tax payments for Lot No. 1702, and the subsequent sale by Alipit to Vitangcol to its prejudice. The non-attachment of the SPA is not fatal, as it can be presented during trial; a motion to dismiss hypothetically admits the truth of the material allegations in the complaint.
Furthermore, the defense of the Statute of Frauds is unavailing. The contract was partially executed, as New Vista had paid the price and was placed in possession of the property. More critically, the principle of equitable estoppel under Article 1431 of the Civil Code applies. By accepting the purchase price and delivering possession of Lot No. 1702 to New Vista in 1989, the Alipits are estopped from denying the authority of their agent or the validity of that sale. They cannot now assert that the agent was only authorized to sell Lot No. 1735 to the detriment of New Vista, a buyer in good faith. Thus, the amended complaint stated a valid cause of action for quieting of title, warranting a full trial on the merits.