📌 CASE TITLE:
Heirs of Roque Naranja v. Lucilia Belardo
G.R. No. 160132 | April 17, 2009 | Supreme Court of the Philippines
⚖️FACTUAL BACKGROUND:
Roque Naranja allegedly sold Lot No. 4 and 1/3 of Lot No. 2 of a subdivision plan in
Bacolod to Lucilia Belardo, his sister, through a Deed of Sale dated August 21, 1981.
However, Roque also executed another Deed of Sale in favor of Dema-ala, which
was used by the heirs of Roque in an extrajudicial settlement and subsequent
transfer of title after his death.
Lucilia Belardo filed a complaint for the cancellation of the extrajudicial settlement
and title, claiming she was the rightful owner based on the earlier deed of sale.
LOWER COURT RULINGS:
Trial Court: Ruled in favor of Belardo; declared her the legal owner of Lot No. 4 and
1/3 of Lot No. 2; ordered cancellation of the extrajudicial settlement and
reinstatement of the previous title (TCT No. T-18764).
Court of Appeals: Affirmed the trial court’s ruling. Denied the heirs' motion for
reconsideration on September 24, 2003.
📚 ISSUES RAISED BY PETITIONERS (Heirs of Roque):
Validity of the Deed of Sale: Argued it was invalid for not complying with Act No. 496
(i.e., it lacked a technical description).
Vitiated Consent: Alleged that Roque’s consent was vitiated by undue influence, lack
of consideration, and notarization irregularities.
⚖️ SUPREME COURT RULING:
1. On the Form of the Deed of Sale:
The SC held that no specific form is required for the validity of a contract of sale of
real property.
Article 1458 of the Civil Code governs sales. As long as there is:
(1) Consent,
(2) A determinate or determinable object,
(3) A price certain in money— — the sale is valid.
The technical description is not essential; the lot numbers, areas, and titles were
enough to identify the properties.
2. On Vitiated Consent and Alleged Undue Influence:
Petitioners failed to present strong, clear, and convincing evidence of undue
influence.
Notarized documents, like the deed of sale, enjoy presumption of regularity.
Atty. Sanicas, the notary public, testified that Roque was mentally sound and even
said he was a law graduate at the time of signing.
3. On Alleged Lack of Consideration:
The Deed of Sale included the line “receipt of which in full I hereby acknowledge,”
which served as acknowledgment of payment.
The SC reiterated the presumption that a contract has sufficient consideration unless
proven otherwise.
Roque’s heirs did not prove otherwise.
4. On Simulation or Fraud:
The late registration of the Deed of Sale did not make it invalid; Belardo simply
lacked funds for registration.
The second deed to Dema-ala was executed only because the title was still in
Roque’s name, not because the first deed was invalid.
5. On the Void Extrajudicial Settlement:
Since the properties were already validly sold to Belardo, they no longer formed part
of Roque's estate.
Thus, the extrajudicial settlement made by the heirs was null and void.
📌 DISPOSITIVE PORTION:
“WHEREFORE, premises considered, the petition is DENIED. The Court of Appeals
Decision dated September 13, 2002 and Resolution dated September 24, 2003 are
AFFIRMED. SO ORDERED.”
🔍 KEY LEGAL PRINCIPLES:
Article 1458, Civil Code: A contract of sale requires consent, a determinate object,
and a price certain.
Notarized Deeds: Presumed valid unless proven otherwise.
Heirs are bound by valid contracts executed by their predecessor.
Undue Influence: Must be proven by clear and convincing evidence.
