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SPS. MARIA BUTIONG v. MA. GRACIA RIÑOZA PLAZO

FACTS:

On November 16, 1989, Pedro L. Riñoza died intestate, leaving several heirs, including his children with his first wife, respondents Ma. Gracia R. Plazo and Ma. Fe Alaras. The heirs discovered that Pedro's second wife, Benita Tenorio, and other children had sold the subject properties to petitioners, spouses Francisco Villafria and Maria Butiong, without their knowledge and consent. Respondents filed a complaint for annulment of the sale and recovery of the subject properties. The trial court ruled in favor of respondents, declaring the transfer of the subject properties null and void. Petitioners denied the allegations and asserted that they only purchased the resort. The trial court ordered the forfeiture of any improvements made by petitioners and ordered them to vacate the premises and deliver possession to the respondents.

The trial court rendered a decision in favor of the heirs and successors-in-interest of Pedro, ordering the defendant Registrar of Deeds to issue the corresponding titles in their names. The Court of Appeals affirmed the trial court's decision, ruling that the resort deed and settlement/family home deed can still be considered valid transactions despite lacking notarization and certain details. However, the burden of proof fell upon the Villafrias to prove the authenticity and due execution of the said deeds, which they failed to do. The trial court's decision was challenged on the grounds of lack of jurisdiction, but the motion for reconsideration was denied by the appellate court.

The petitioner filed a Petition for Review on Certiorari with the Supreme Court but failed to comply with the requirements of the 2004 Rules on Notarial Practice. The Supreme Court denied the petition for failure to comply with procedural requirements. The petitioner then sought leave to admit a second motion for reconsideration, which was also denied by the Court. The Regional Trial Court issued a partial writ of execution, and the petitioner filed a Petition for Annulment of Judgment and Order before the Court of Appeals. The CA dismissed the petition and affirmed the rulings of the trial court, stating that there was no extrinsic fraud or lack of jurisdiction. The CA also noted that if the petitioner lost their chance to avail themselves of the appropriate remedies, it was their own responsibility.

The petitioner filed a Petition for Review on Certiorari, arguing that the trial court acted without jurisdiction in entertaining a special proceeding for the settlement of the estate and a civil action for annulment of title in one proceeding. The petitioner asserts that the settlement of the estate should be handled by a probate court of limited jurisdiction, while judicial partition with annulment of title is a separate civil action.

ISSUES:

  1. Whether the Regional Trial Court (RTC) had jurisdiction over the complaint for Judicial Partition with Annulment of Title and Recovery of Possession.

  2. Whether the conveyances of the properties to petitioners were valid and in good faith.

RULING:

  1. Jurisdiction of the RTC:

    • The Supreme Court ruled that the action filed was for judicial partition with annulment of title and recovery of possession, not a special proceeding for the settlement of the estate. The RTC had jurisdiction as provided under Section 1, Rule 69 of the Rules of Court and Section 1 of Republic Act No. 7691. The respondents' complaint was properly within the law as the estate was without debts.

    • It also ruled that the petitioner's active participation in the case prevented them from later impugning the court’s jurisdiction.

  2. Validity of the Conveyances:

    • The Supreme Court upheld the findings of the RTC and CA that the conveyances to the petitioners were irregular. The Extra-Judicial Settlement and Deed of Sale were not sufficiently proven and had several defects, including being undated and unsigned by one party, and notarized by a person not commissioned at the time of notarization.

    • The petitioners were found not to be innocent purchasers for value and builders in good faith due to the legal infirmities of the documents, absence of consideration evidence, and discrepancies in their testimonies regarding the properties bought.

PRINCIPLES:

  1. Jurisdiction and Active Participation:

    • Active participation in a case signifies recognition of the court’s jurisdiction and willingness to abide by the court's resolution.

  2. Notarial Act Validity:

    • A document notarized by someone who is not officially authorized or commissioned at the time of notarization is treated as an unnotarized document and does not enjoy the presumption of regularity.

  3. Principle of Immutability of Judgments:

    • Once a judgment has become final and executory, it becomes immutable and unalterable, except under extraordinary circumstances such as lack of jurisdiction or fraud.

  4. Annulment of Title and Recovery of Ownership:

    • Issues of ownership and validity of notarization can be addressed within an action for partition.

  5. Good Faith in Property Transactions:

    • Good faith requires belief that the builder or purchaser owns the land or has no knowledge of any defect in the title. Significant legal infirmities in conveyance documents negate claims of good faith.