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HEIRS OF ROMANA SAVES v. HEIRS OF ESCOLASTICO SAVES

FACTS:

The case involved the heirs of Romana Saves, Rafaela Saves, Januaria Saves, Maximo Saves, and Benedicta Saves, who filed a case for Reconveyance, Partition, and Damages before the Regional Trial Court of Negros Oriental. They claimed that Lot No. 382, originally titled in their names, was fraudulently acquired by Gaudencia Valencia and subsequently sold to Enriqueta Chavez Abella. The plaintiffs asserted their entitlement to their shares in the property. Transfer Certificate of Title No. 148 was issued to Gaudencia Valencia, who later sold the property to Enriqueta Chavez Abella.

During the pre-trial stage, the parties failed to reach an amicable settlement, agreeing to exclude Lot 386 from the litigation. The issues were limited to the ownership of lots 382 and 383. Trial proceeded, and the trial court ruled in favor of the petitioners. The trial court declared the Deed of Sale and Deed of Absolute Sale null and void, ordering Enriqueta Chavez Abella to convey and deliver the petitioners' shares of Lot No. 382. Additionally, Abella was directed to pay litigation expenses, counsel appearances, and moral damages. The claim for Lot No. 383 was dismissed.

Respondents appealed the trial court's decision to the Court of Appeals, resulting in the reversal of the trial court's ruling and the dismissal of the complaint. The petitioners then filed a motion for reconsideration, which was subsequently denied. Undeterred, the petitioners appealed to the Supreme Court, raising several issues concerning the consideration of evidence not formally offered and the failure to declare Abella a purchaser and registrant in bad faith.

ISSUES:

  1. Whether or not the Court of Appeals erred in considering Exhibits "7" and "13" as evidence despite not being formally offered by the trial court.

  2. Whether or not Exhibits "7" and "13" comply with the requirements set forth in People v. Napat-a and People v. Mate.

  3. Whether the Court of Appeals erred in failing to consider that respondent Abella is a purchaser in bad faith.

  4. Whether respondent Abella is a purchaser in good faith.

  5. Whether the contracts executed by the parties are null and void

  6. Whether respondent Abella is a purchaser in good faith

  7. Whether petitioners are barred from asserting their claims over the property due to estoppel by laches

RULING:

  1. The Court of Appeals did not err in considering Exhibits "7" and "13" as evidence despite not being formally offered by the trial court. The court has the discretion to determine whether an exhibit serves its probative purpose, even if it was not formally offered. However, the requirements set forth in the case of People v. Napat-a and People v. Mate must be complied with.

  2. Exhibits "7" and "13" comply with the requirements set forth in People v. Napat-a and People v. Mate. The records show that these exhibits were duly identified by testimony duly recorded and were incorporated into the records of the case. Therefore, they can be considered as evidence in the case.

  3. The Court of Appeals did not err in failing to consider that respondent Abella is a purchaser in bad faith. The issue of good faith or bad faith was not raised in the Complaint filed by the petitioners in the RTC. Furthermore, during trial, it was established that respondent Abella was already married to Charles Abella when she bought the lot and the purchase money was provided by her husband. As a result, the trial court's declaration that respondent Abella is a purchaser in bad faith was reversed by the Court of Appeals.

  4. The Court of Appeals ruled that respondent Abella is an innocent purchaser for value and in good faith. Records reveal that she derived her title from Gaudencia Valencia, the previous owner, and relied on the face of the Transfer Certificate of Title, which was free from any encumbrances or annotations. The Court agrees with this ruling, citing the well-settled doctrine that a purchaser dealing with property registered under the Torrens system need not go beyond the title and is charged with notice only of burdens and claims annotated on the certificate. Additionally, the burden to prove that respondent Abella had notice of any defect in the title of her predecessor lies with the petitioners, which they failed to substantiate. Furthermore, respondent Abella was in possession of the property, while the petitioners were never in possession and only learned of their possible claim much later.

  5. The contracts executed by the parties are not deemed null and void based on the discussions of the Court of Appeals. The defendant, Abella, had no participation in the execution of the contracts and had no reason to believe that they were anything other than what they purported to be on their face.

  6. Respondent Abella is considered a purchaser in good faith. She bought the property without notice of any adverse claims or interests and paid its fair price before having any knowledge of such claims or interests.

  7. Petitioners are barred from asserting their claims over the property due to estoppel by laches. They failed to assert their rights and delayed in asserting their claims after the discovery of the allegedly fictitious deeds of sale. They also never took possession of the property or filed any adverse claim against the ownership of Gaudencia Valencia.

PRINCIPLES:

  • A court shall consider no evidence that has not been formally offered. The purpose for which the evidence is offered must be specified. A formal offer is necessary for the trial judge to know the purpose of the evidence and for the opposing parties to examine and object to its admissibility. This also facilitates review by the appellate court (Section 34, Rule 132 of the Revised Rules of Court).

  • Evidence not formally offered may be admitted and considered by the trial court if it has been duly identified by testimony duly recorded and duly incorporated in the records of the case (People v. Napat-a and People v. Mate).

  • An admission, verbal or written, made by a party in the course of the proceedings in the same case does not require proof and may only be contradicted by showing that it was made through palpable mistake or that no such admission was made.

  • A purchaser dealing with property registered under the Torrens system need not go beyond the title and is charged with notice only of burdens and claims annotated on the certificate.

  • The burden to prove that a purchaser had notice of any defect in the title of their predecessor lies with the party making the claim.

  • A purchaser in good faith is one who buys property without notice of any adverse claims or interests and pays its fair price before having any knowledge of such claims or interests.

  • Laches is the failure to assert a right for an unreasonable and unexplained length of time, warranting a presumption that the party entitled to assert it has abandoned or declined to assert it.