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RAQUEL CHAVEZ v. IAC

FACTS:

This case involves a dispute over the ownership of a parcel of land in Camarines Norte. The land is the paraphernal property of petitioner Manuela Buenavista, who has six children named Antonio, Rosario, Concepcion, Raquel, Presentacion, and Floserpina. A series of sales took place involving the undivided shares of the children in the land. On July 11, 1958, Presentacion sold her 1/6 undivided share to Concepcion. Two years later, Floserpina also sold her 1/6 undivided share to Concepcion. On May 19, 1960, Raquel sold her undivided 1/6 share to Concepcion. As a result, Concepcion became the owner of a total undivided 4/6 share of the land, while Antonio and Rosario owned the remaining 2/6 shares. The sales documents stated that the land had been assigned or distributed to the children by Manuela Buenavista, subject to her lifetime usufruct.

However, on August 27, 1968, Manuela signed a sale of the entire property in favor of her daughter Raquel and her husband Gerardo Jimenez. Subsequently, Manuela sold the entire property to Pepito Ferrer on February 4, 1969, with a right to repurchase. Antonio, Rosario, and Concepcion filed a complaint against Manuela and Raquel, leading to a trial wherein the trial court dismissed the complaint. The plaintiffs appealed to the Court of Appeals, which reversed the trial court's decision. The Court of Appeals declared the sales made to Raquel and Gerardo, as well as the sale to Pepito Ferrer, null and void. The court also recognized the earlier deeds of sale as evidence of a valid partition of the land between Manuela and her children, subject to Manuela's lifetime usufruct.

ISSUES:

  1. Whether the sale made by Manuela Buenavista of her property in favor of the spouses Raquel Chavez and Gerardo Gimenez is valid.

  2. Whether the earlier deeds of sale signed by Manuela and her children constitute a valid partition of the land.

RULING:

  1. The sale made by Manuela Buenavista of her property in favor of the spouses Raquel Chavez and Gerardo Gimenez is declared null and void ab initio.

  2. The earlier deeds of sale signed by Manuela and her children constitute a valid partition of the land, subject to Manuela's right of usufruct during her lifetime.

PRINCIPLES:

  • A sale made by a property owner with the intent to deceive and defraud others is considered null and void ab initio.

  • An agreement or partition involving the distribution of property among co-owners is valid as long as it conforms to the requisites of a valid contract and complies with the formalities required by law.

  • Usufruct, as a right in real property, grants a person the right to enjoy the property and its fruits, while the ownership remains with another person.