G.R. No. L-23516 June 25, 1980
CANDIDO SAN LUIS, et al., plaintiffs-appellants, vs. TOMASA SAN LUIS NEGRETE, et al., defendants-appellees.
FACTS
The plaintiffs, heirs of Felipe San Luis, sought the annulment of a deed of absolute sale dated May 9, 1956, wherein Felipe and four of his children sold a parcel of land to his daughters, defendants Tomasa San Luis Negrete and Rosario San Luis Suson. The plaintiffs alleged the sale was simulated and lacked valid consideration. The land was originally registered in the name of Felipe San Luis under OCT No. 0-7. During the pendency of the land registration proceedings, the sale was executed. After Felipe’s death, the defendants successfully petitioned the registration court to cancel OCT No. 0-7 and issue a new title in their names. The trial court upheld the validity of the sale but ordered the defendants to pay a sum to the heirs, absolving Tomasa and her husband.
The property was conjugal, owned by Felipe San Luis and his predeceased wife, Encarnacion Rodriguez. Felipe could only dispose of his own share (one-half of the whole) and his hereditary portion from his wife. The four children who signed the deed could only convey their respective hereditary shares. Other heirs, including plaintiff Candido San Luis, did not participate in the sale. Evidence showed Felipe had complained about non-payment, and the vendors remained in possession and collected rentals, but the defendants presented the deed with consideration stated.
ISSUE
The primary issue was whether the deed of absolute sale was valid and effective to convey full ownership of the entire property to the defendants.
RULING
The Supreme Court reversed the trial court’s decision. It ruled the deed of sale was valid but only to the extent of the shares lawfully conveyed by the vendors. The land being conjugal, Felipe San Luis owned one-half, and the other half belonged to the estate of his wife, Encarnacion, to be inherited equally by their nine children. Felipe could only sell his one-half conjugal share and his one-ninth hereditary share in the other half. The four children who signed could only sell their individual one-ninth hereditary shares. Thus, the vendors collectively conveyed only 17/20 of the entire property (Felipe’s 1/2 + 5/9 of the remaining 1/2). The remaining 3/20 belonged to the non-selling heirs, including Candido San Luis and the children of Remedios and Jose San Luis.
The Court found no proof the sale was simulated. The disputable presumptions that a transaction is fair, regular, and supported by consideration were not overcome. However, the registration court erred in ordering the issuance of a new title solely in the defendants’ names, as they did not acquire the entire property. The Supreme Court ordered the cancellation of the title and the issuance of a new one reflecting the proportionate shares: 17/20 to the defendant-vendees and 1/20 each to Candido San Luis, the children of Remedios San Luis Benjil, and the children of Jose San Luis.