LUCIA CARLOS ALIÑO v. HEIRS OF ANGELICA A. LORENZO

FACTS:

The case involves a parcel of land in Cotabato City, registered in the name of petitioner Lucia Carlos Aliño under Transfer Certificate of Title (TCT) No. T-15443. On April 2, 1979, Lucia's daughter, Angelica A. Lorenzo, bought the land for P10,000.00 under a Deed of Absolute Sale. TCT No. T-15443 was canceled and TCT No. T-15500 was issued in Angelica's name. Lucia continued to pay the real estate taxes on the land under her name, and she designated Vivian Losaria as the caretaker. Angelica died on October 3, 1985, leaving behind her husband, Servillano Sr., and their eight children as surviving heirs. In 1988, the heirs executed an Extra-Judicial Settlement of Angelica's estate, and the subject land was adjudicated to three of her minor children. Meanwhile, Lucia executed documents indicating her intent to sell the land to the Central Bank of the Philippines (CBP) and demanded the return of the land from Servillano Sr. When the demand was not met, Lucia filed a complaint in 1989 against the heirs of Angelica. The Regional Trial Court (RTC) dismissed the complaint, ruling that the sale was not simulated. The Court of Appeals (CA) affirmed the decision of the RTC but deleted the award for attorney's fees. Dissatisfied, the petitioners filed a Petition for Review on Certiorari.

ISSUES:

  1. Whether or not the Deed of Absolute Sale executed by Lucia in favor of Angelica is valid and binding upon the parties.

RULING:

  1. The Court finds for the petitioners and declares that the Deed of Absolute Sale executed by Lucia in favor of Angelica is invalid and not binding upon the parties. The Court holds that the sale was simulated based on the absence of any attempt by Angelica or Servillano, Sr. to assert dominical rights over the subject property, and considering Lucia's continuous and adverse possession of the property and payment of real property taxes.

PRINCIPLES:

  • The findings of facts of the Court of Appeals are conclusive and binding on the Supreme Court, except for well-recognized exceptions.