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RAUL SANTOS BY v. HEIRS OF JOSE P. MARIANO

FACTS:

The case involves a dispute over six parcels of land owned by spouses Macario A. Mariano and Irene Peña-Mariano. Macario passed away, and his share of the land was inherited by Irene, Jose Mariano, and Erlinda Mariano-Villanueva. An Indenture of Extra-Judicial Settlement of Estate was executed, appointing Irene as the representative and agent of the heirs. Irene then executed an Affidavit of Merger, merging the land titles under her name.

Subsequently, Irene married Rolando Relucio, but their marriage was annulled due to Rolando's prior existing marriage. During their marriage, Irene sold the six parcels of land to Raul Santos. Additionally, she sold Lot No. 612 to Greta Tinga de los Reyes, who later sold it to Bonifacio Sia, Jr. Irene continued to possess and manage the properties until her death.

After Irene's death, Jose and Erlinda discovered the sale of the land to Raul and questioned the validity of the deeds of sale. They filed administrative complaints against the notary who notarized the deeds, but the Supreme Court absolved the notary from liability. Subsequently, Jose and Erlinda filed a case against Rolando, Raul, and the Register of Deeds of Naga City for the annulment of the sale with damages.

Later, they discovered another deed of sale executed by Irene in favor of Raul, prompting them to file another case for the annulment of the title and the second deed of sale.

ISSUES:

  1. Whether the contracts of sale between Irene Peña-Mariano and the vendees were valid and binding.

  2. Whether the transfer certificates of title in the name of Raul Santos and Amado Sanao should be cancelled and new titles be issued in the name of the heirs of Irene P. Mariano.

  3. Whether the contracts of sale in question are valid and binding.

  4. Whether the Court of Appeals erred in granting a motion for new trial based on newly discovered evidence.

  5. Whether the Court of Appeals committed grave abuse of discretion in restoring possession and administration of the subject properties to the plaintiffs-appellants.

RULING:

  1. The Court of Appeals declared the contracts of sale dated 15 April 1975, 10 March 1982, and 09 August 1990 as null and void. The transfer certificates of title issued in the name of Raul Santos and Amado Sanao were ordered to be cancelled and new titles be issued in the name of the heirs of Irene P. Mariano.

  2. Defendants-appellees were ordered to pay plaintiffs-appellants moral damages and attorney's fees. Plaintiff-appellant Erlinda M. Villanueva was also ordered to pay intervenor-appellant Law Firm of San Buenaventura Moraleda Obias and Yambao attorney's fees.

  3. The contracts of sale in question are not valid and binding. The evidence presented in the lower courts showed that there was no meeting of the minds between the sellers and buyers of the properties. The due execution of the written documents does not determine the validity of a contract if there was no intention to sell the properties. Therefore, the subject contracts of sale are null and void.

  4. The Court of Appeals did not err in granting the motion for new trial based on newly discovered evidence. The petitioner had the opportunity to assail the ruling but chose not to do so. He participated in the hearing and cannot now contest the evidence presented.

  5. The discussion of the third issue is deemed moot and academic since the first two assigned errors were dismissed.

PRINCIPLES:

  • Contracts that are found to be null and void may be declared as such by the court.

  • When contracts are declared null and void, the corresponding transfer of title may be cancelled and new titles may be issued in favor of the rightful owners.

  • Parties may be entitled to damages and attorney's fees depending on the circumstances of the case.

  • The validity of a contract is determined by the presence of the elements constituting a contract, including the consent of the parties, a certain object, and cause of obligation.

  • The due execution of a written document does not determine the validity of a contract if there was no meeting of the minds between the parties.

  • Procedural rules are designed to give effect to lawful and valid claims, not to frustrate them.