G.R. No. 230573 , June 28, 2021
THE HEIRS OF ANSELMA GODINES, NAMELY: MARLON, FRANCISCO, ROQUE, ROSA AND ALMA, ALL SURNAMED GODINES, PETITIONERS, VS. PLATON DEMAYMAY AND MATILDE DEMAYMAY, RESPONDENTS.

FACTS

Petitioners are the heirs of Anselma Yuson Godines, who died in 1968, leaving a residential lot in Masbate. Respondents, spouses Platon and Matilde Demaymay, are in possession of the land, claiming Anselma sold it to them orally in January 1967 for P1,460.00, with an initial payment of P1,010.00. No written contract was executed as Anselma was about to give birth, and she and her husband died before a formal deed could be made. In 1970, petitioner Alma (then about 14 years old) and an uncle executed a Deed of Confirmation of Sale upon full payment, leading to the property being tax-declared under Matilde’s name. In 1987, petitioners discovered the tax declaration in Anselma’s name was cancelled and a new one issued to Matilde. They filed a Complaint for Recovery of Ownership and Possession and Declaration of the Deed of Confirmation as Null and Void with Damages before the RTC, arguing Alma could not have executed the deed as she was a minor and elsewhere at the time. The case was transferred to the MCTC due to the property’s assessed value. The MCTC initially dismissed the case but, after remand and proceedings, ruled in favor of petitioners, declaring them owners and nullifying the Deed. The RTC affirmed this on appeal. The Court of Appeals reversed, recognizing the spouses Demaymay as owners and ordering petitioners to execute a Deed of Absolute Sale.

ISSUE

Whether the Court of Appeals gravely erred in ruling that the heirs of Anselma are bound by the oral contract of sale allegedly executed in favor of the spouses Demaymay.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals. The core issue was the validity of the oral sale between Anselma and the spouses Demaymay, not merely the Deed of Confirmation. The Court held that oral contracts of sale are valid and enforceable under Article 1356 of the Civil Code, provided all essential requisites (consent, object, cause) are present. While Article 1358 requires sales of real property to appear in a public document, this is for convenience, not validity. The Statute of Frauds (Article 1403) requires certain contracts, including sales of real property, to be in writing to be enforceable. However, an oral sale is enforceable if it has been partially or fully executed. Here, the contract was partially executed through the delivery of possession to the buyers and payment of the purchase price (initial payment to Anselma, full payment leading to the 1970 Deed). The spouses Demaymay’s possession for over the 15-year lease period claimed by petitioners, and their payment of real property taxes, were indicators of the sale’s execution. Therefore, the oral sale was valid and enforceable. Consequently, the property no longer formed part of Anselma’s estate, and petitioners, as heirs, were bound by the sale. The Court ordered the denial of the petition and affirmed the CA Decision and Resolution.