GR 115938; (October, 1997) (Digest)
March 11, 2026GR 242132; (September, 2019) (Digest)
March 11, 2026G.R. No. L-3813; January 30, 1953
PAUKI, TABUACAR, ORANGAGA, and DAYANG all surnamed MADALE, plaintiffs-appellants, vs. PASEYANAN BAY SA RAYA, and BUAT ALONTO, defendants-appellees.
FACTS
The plaintiffs, Pauki, Tabuacar, Orangaga, and Dayang Madale, were joint owners of a piece of land in Dansalan, Lanao, inherited from their deceased father. They filed an action to quiet title against defendants Paseyanan Bay Sa Raya and Buat Alonto, alleging the defendants had taken possession without right. The defendants claimed ownership based on a deed of sale (Exhibit 1) executed on April 6, 1940, by plaintiff Pauki Bayalabi Madali (with her husband’s consent) in favor of Paseyanan Bay Sa Raya, and a subsequent deed of sale (Exhibit 2) executed by Paseyanan on August 20, 1945 (with her husband’s consent) in favor of Buat Alonto. Initially, plaintiffs attempted to prove Exhibit 1 was a mortgage but abandoned this. The controversy was confined to the issue of the validity of Exhibits 1 and 2, with the parties stipulating that if the documents were valid, judgment would be for the defendants, and if void, for the plaintiffs, without costs. The trial court held Exhibit 1 valid, ruling that Sections 145 and 146 of the Administrative Code of Mindanao and Sulu, requiring provincial governor approval for contracts relating to real property involving Moros or non-Christian inhabitants, did not apply to contracts where all parties are non-Christians. It therefore dismissed the complaint.
ISSUE
Whether the deeds of sale (Exhibits 1 and 2) come within the provisions of Sections 145 and 146 of the Administrative Code of Mindanao and Sulu, requiring approval of the provincial governor for validity, given that all parties to the contracts are non-Christians.
RULING
The Supreme Court reversed the trial court’s decision. It held that Sections 145 and 146 of the Administrative Code of Mindanao and Sulu apply to the deeds in question. The law’s evident purpose is to safeguard the patrimony of less developed ethnic groups by shielding them from imposition and fraud in real property agreements. The law makes no distinction between contracts between a Christian and a non-Christian and those where all parties are non-Christians, as fraud is possible in both cases. The trial court’s construction arbitrarily curtailed the law’s scope, contrary to rules of statutory construction and the precedent in Porkan vs. Navarro (73 Phil., 699), which held that the lawmakers did not make such a distinction and the courts cannot supply it. Therefore, the deeds executed without the required approval are null and void. Judgment was rendered declaring the plaintiffs as the owners of the property in controversy. No costs were awarded, in accordance with the parties’ stipulation.

