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ROGELIO DANTIS v. JULIO MAGHINANG

FACTS:

The case involves a complaint for quieting of title and recovery of possession with damages filed by petitioner Rogelio Dantis against respondent Julio Maghinang Jr. Rogelio claimed to be the registered owner of a parcel of land covered by Transfer Certificate of Title No. T-125918 located in Bulacan. He alleged that he acquired ownership of the property through a deed of extrajudicial partition of the estate of his deceased father. He also claimed that Julio Jr. occupied and built a house on a portion of his property without any right, and that demands for Julio Jr. to vacate the premises were ignored. As a result, Rogelio's title and right of possession were clouded. He prayed for a judgment declaring him as the true owner of the property, ordering Julio Jr. to deliver possession of the portion he occupied, and directing Julio Jr. to pay rentals and attorney's fees. In his Answer, Julio Jr. denied the material allegations of the complaint and claimed that he was the actual owner of the portion of the land he was occupying. According to Julio Jr., the land was once tenanted by his ancestral relatives and was sold to his father by Rogelio's father. The RTC rendered a decision in favor of Rogelio, declaring him as the true owner of the entire lot. The RTC did not give any probative value to Julio Jr.'s documentary evidence to support his claim of ownership.

This case revolves around a disputed parcel of land located in Bulacan, Philippines. The land was covered by Transfer Certificate of Title No. T-125918 in the name of Rogelio Dantis and his spouse Victoria Payawal. Julio Maghinang, Jr., on the other hand, claimed ownership of a 352-square meter portion of the land, which is where his residence is located. Julio Jr. relied on Exhibit "4," a document which he argued was proof of a sale between his father, Julio Sr., and Emilio, the predecessor-in-interest of Rogelio. Exhibit "4" was claimed to be an oral contract of sale which was partially paid and the res (property) already delivered. Julio Jr. sought reconveyance of the disputed portion of the land based on his equitable claim.

The Regional Trial Court (RTC) ruled that Exhibit "4" did not establish a perfected contract of sale and found Julio Jr. to be a mere possessor by tolerance. It declared Rogelio as the true and lawful owner of the entire land covered by TCT No. T-125918. Julio Jr. appealed the RTC decision to the Court of Appeals (CA), which reversed the RTC decision. The CA held that Exhibit "4" was a valid proof of sale and ordered the reconveyance of the 352-square meter portion to Julio Jr. or his heirs, subject to partition. Rogelio filed a petition for review on certiorari before the Supreme Court, essentially challenging the existence and admissibility of Exhibit "4" and asserting his rights as a transferee in good faith.

ISSUES:

  1. Whether there was a perfected contract of sale between Emilio Dantis and Julio Maghinang, Sr.

  2. Whether Julio, Jr. can claim ownership over the 352-square meter portion of land based on the alleged oral sale.

RULING:

  1. No, there was no perfected contract of sale between Emilio Dantis and Julio Maghinang, Sr. The alleged receipt (Exhibit "4") was found to be inadmissible as evidence. Even if admissible, it did not provide a determinate subject matter or price and failed to show the essential requisites of a contract of sale.

  2. No, Julio, Jr. cannot claim ownership over the 352-square meter portion of land because the evidence to support the alleged sale was insufficient, and he failed to prove a valid defense against Rogelio's ownership.

PRINCIPLES:

  1. Burden of Proof: The party who alleges a fact has the burden of proving it with a preponderance of evidence.

  2. Hearsay Rule: Affidavits not identified and affirmed by the affiant in court are considered hearsay and inadmissible as evidence.

  3. Best Evidence Rule: The highest evidence degree must be produced. Secondary evidence is admissible only upon proving the unavailability of the original without bad faith.

  4. Statute of Frauds: A contract of sale that is not in writing and signed by the party to be charged is unenforceable if not performed partly but presupposes the existence of a perfected contract.

  5. Essentials of a Contract of Sale: The elements include consent, determinate subject matter, and price certain in money or its equivalent. Absence of any of these elements means no perfected contract.