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Spouses Maria Butiong and Francisco Villafria vs. Ma. Gracia Riñoza Plazo and Ma. Fe Riñoza Alaras

The Supreme Court ruled on the case involving spouses Maria Butiong and Francisco Villafria against Ma. Gracia Riñoza Plazo and Ma. Fe Riñoza Alaras, affirming the lower courts' decisions that invalidated the sale of properties due to irregularities in the documentation. The Court confirmed that the Regional Trial Court had jurisdiction over the action for judicial partition and annulment of title, and emphasized the necessity for proper execution of property documents. Furthermore, the petitioners were deemed not to be innocent purchasers for value, as they failed to exercise due diligence in investigating the legitimacy of the sale.

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66 views2 pages

Spouses Maria Butiong and Francisco Villafria vs. Ma. Gracia Riñoza Plazo and Ma. Fe Riñoza Alaras

The Supreme Court ruled on the case involving spouses Maria Butiong and Francisco Villafria against Ma. Gracia Riñoza Plazo and Ma. Fe Riñoza Alaras, affirming the lower courts' decisions that invalidated the sale of properties due to irregularities in the documentation. The Court confirmed that the Regional Trial Court had jurisdiction over the action for judicial partition and annulment of title, and emphasized the necessity for proper execution of property documents. Furthermore, the petitioners were deemed not to be innocent purchasers for value, as they failed to exercise due diligence in investigating the legitimacy of the sale.

Uploaded by

Rigin Amay
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as DOCX, PDF, TXT or read online on Scribd
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14

Spouses Maria Butiong and Francisco


Villafria vs. Ma. Gracia Riñoza Plazo and
Ma. Fe Riñoza Alaras
G.R. No. 187524
August 5, 2015.

Facts:

 Pedro L. Riñoza died intestate on November 16, 1989, leaving behind


several heirs, including his children from his first marriage,
respondents Ma. Gracia R. Plazo and Ma. Fe Alaras.
 In March 1991, respondents discovered that their co-heirs, including
Pedro's second wife, Benita Tenorio, had sold certain properties in
Nasugbu, Batangas, to Spouses Francisco Villafria and Maria Butiong
without their knowledge or consent.
 The documents evidencing the sale, such as the Extra-Judicial
Settlement and Deed of Sale, contained irregularities, including
unauthorized notarization and missing signatures.
 Respondents filed a complaint for judicial partition, annulment of title,
and recovery of possession, alleging that the sale was conducted
clandestinely and without their consent.

Issues:

1. Whether the Regional Trial Court (RTC) had jurisdiction to entertain an


action for judicial partition and annulment of title in a single
proceeding.
2. Whether the Extra-Judicial Settlement and Deed of Sale were valid and
binding.
3. Whether the petitioners were innocent purchasers for value and
builders in good faith.

Ruling:

The Supreme Court ruled as follows:


1. Jurisdiction: The RTC had proper jurisdiction over the action for
judicial partition, annulment of title, and recovery of possession. The
Court emphasized that when a person dies intestate and without
debts, the heirs may either extrajudicially or judicially partition the
estate without the need for a separate special proceeding for
settlement.
2. Validity of Documents: The Extra-Judicial Settlement and Deed of
Sale were declared invalid due to several irregularities, such as
unauthorized notarization and missing signatures. These defects
rendered the documents void and without legal effect.
3. Good Faith: The petitioners were not considered innocent purchasers
for value or builders in good faith. The evident defects in the
documents should have prompted them to investigate further.
Additionally, actions like demolishing existing structures on the
property indicated bad faith.

The Court affirmed the decisions of the lower courts, nullifying the transfer of
the subject properties to the petitioners and ordering the return of
possession to the respondents.

Doctrine:

This case underscores that Regional Trial Courts have jurisdiction over
actions for judicial partition, even when accompanied by prayers for
annulment of titles and recovery of possession. It also highlights the
importance of ensuring the authenticity and proper execution of documents
affecting property rights and cautions purchasers to exercise due diligence
to qualify as buyers in good faith.

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