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SPS. LEOPOLDO GARRIDO v. CA

FACTS:

The disputed land in this case was owned by spouses Maria Abaquita and Juan Jimenez. During their lifetime, several tenants occupied a portion of the lot and built houses, paying rent to Abaquita. After the death of the spouses, their daughter Regina Jimenez disputed ownership of the land with her own daughter, Natividad Evangelista. Regina Jimenez then offered half of the lot to petitioner Luz Garrido for a certain amount, entering into an option to buy agreement. Later on, Regina Jimenez and Natividad Evangelista divided the lot into two portions and obtained separate land titles. The houses of the respondent lessees were located on the portion adjudicated to Regina Jimenez. Subsequently, Regina Jimenez sold her portion to the petitioner Garrido spouses. Upon learning about their ownership, the respondent lessees refused to vacate and stopped paying rent. They filed a complaint seeking the annulment of the sale and cancellation of the title issued to the petitioner Garrido spouses. Initially, the trial court ruled in favor of the petitioners, but the Court of Appeals partially annulled the sale and allowed some of the respondent lessees to purchase the area they occupied.

ISSUES:

  1. Whether the deed of sale and Transfer Certificate of Title issued in favor of petitioner Garrido spouses should be annulled.

  2. Whether the respondent lessees should be allowed to purchase the area leased to them.

RULING:

  1. The Court of Appeals affirmed the dismissal of the complaint as far as one of the respondent lessees is concerned, but reversed the dismissal with respect to the other plaintiffs. The deed of sale and Transfer Certificate of Title issued in favor of petitioner Garrido spouses were partially annulled with respect to the area occupied by the other plaintiffs.

  2. The Court of Appeals ruled that the other plaintiffs, namely, Lolita Sanchez, Erlinda Aquino, and Emilia Marqueda, should be allowed to purchase the area leased to them.

PRINCIPLES:

  • Partial annulment of a deed of sale and Transfer Certificate of Title is possible if only a portion of the property is disputed and there is evidence to support such dispute.

  • A Lessee may be allowed to purchase the area leased to them if there are valid grounds for doing so.