GR 228999; (April, 2021) (Digest)
G.R. No. 228999 , April 28, 2021
ANA DE JOYA AND CIRIACO DE JOYA, LERMA R. CASTILLO AND MARIO CASTILLO, SPOUSES DOMINGO CORDERO AND LEONCIA CORDERO, AND RICARDO VILLALOBOS, AS THE SURVIVING HEIRS OF SPOUSES EUFRONIO CORDERO AND TARCILA C. CORDERO, PETITIONERS, VS. FRANCISCO P. MADLANGBAYAN, SUBSTITUTED BY RODESINDA F. MADLANGBAYAN AND MARIA LOURDES M. MONTALBO, THE REGISTER OF DEEDS FOR THE PROVINCE OF BATANGAS, SPOUSES ROLANDO DALIDA AND MARIA FLORITA DALIDA, SPOUSES GEORGE GULLET AND CONCHITA GULLET, SPOUSES ROSENDO RAMOS AND ISABELITA RAMOS, RENATO GO, CHOLLIE MAGNAYE-GO, VENECIO H. MAGNAYE, CRISTETA SALCEDOMAGNAYE AND JAYSON MAGNAYE, RESPONDENTS.
FACTS
Petitioners were the registered owners of two parcels of agricultural land (Lot Nos. 5 and 6) covered by TCT No. T-64767. They granted respondent Francisco P. Madlangbayan authority to sell the properties via a Special Power of Attorney. In April 1996, respondents Dalida, et al. made a counter-offer to buy the properties. Petitioners, through Madlangbayan, rejected this counter-offer in a letter dated April 10, 1996, stating the price of P17,000,000.00 was non-negotiable. Subsequently, petitioners revoked Madlangbayan’s authority on May 3, 1996, due to a disagreement over his commission. Petitioners later discovered that a Deed of Absolute Sale dated April 8, 1996, had been executed by Madlangbayan selling the properties to respondents Dalida, et al. for P10,000,000.00, contrary to their rejection. Petitioners filed a complaint for revocation of authority and a supplemental complaint alleging a fake deed of sale and conspiracy. The Regional Trial Court initially upheld the sale, finding respondents Dalida, et al. to be buyers in good faith. Upon grant of a new trial based on newly discovered evidence, the RTC later ruled in favor of petitioners, finding the sale price was simulated and unpaid, and that respondents Dalida, et al. were not in good faith. The Court of Appeals reversed this and remanded the case. After further proceedings, the RTC again ruled for petitioners, declaring the Deed of Absolute Sale void. The Court of Appeals, in the assailed Decision, reversed the RTC and upheld the validity of the sale.
ISSUE
Whether the Deed of Absolute Sale dated April 8, 1996, executed by respondent Madlangbayan in favor of respondents Dalida, et al. is valid and binding upon the petitioners.
RULING
No. The Supreme Court granted the petition, reversed the Court of Appeals Decision, and reinstated the Regional Trial Court’s Judgment dated December 10, 2014. The Court ruled that the Deed of Absolute Sale was void. There was no perfected contract of sale between the petitioners and respondents Dalida, et al. because there was no consent or meeting of the minds. The petitioners’ counter-offer rejection letter dated April 10, 1996, proved they did not accept the buyers’ proposal. The subsequent Deed of Absolute Sale dated April 8, 1996, was simulated, as it reflected a price (P10,000,000.00) contrary to the petitioners’ firm demand (P17,000,000.00). A simulated contract is void. Furthermore, respondent Madlangbayan’s authority as agent was revoked by the petitioners before the sale was finalized, and the agent acted beyond his authority. The Court also found that respondents Dalida, et al. were not buyers in good faith and in fact acted in bad faith, as they were aware of the petitioners’ rejection of their offer and the subsequent revocation of the agent’s authority.