Case 1

Facts:
 Maxima Castro obtained a loan from Rural Bank of Caloocan with the assistance of
Severino Valencia.
 Valencia arranged the loan and provided the necessary personal data for Castro's loan.
 On the same day, the Valencia spouses also obtained a loan from the bank and caused
Castro to sign as a co-maker in their promissory note.
 Both loans were secured by a real estate mortgage on Castro's property.
 The mortgage was foreclosed and the property was sold at a public auction.
 Castro filed a complaint against the bank, alleging that the Valencias fraudulently
induced her to sign as a co-maker and to constitute a mortgage on her property.
 Castro deposited the amount of her personal loan plus interest with the Clerk of Court.
 The trial court declared the promissory note, mortgage contract, and auction sale null
and void.
 The amount deposited by Castro was ordered to be applied to her personal loan.
 The Court of Appeals affirmed the decision.
Issue:
 Whether the contracts were void due to fraud and misrepresentation.
 Whether the consignation made by Castro was valid.
 Whether the auction sale was null and void.
Ruling:
 The contracts were declared void due to substantial mistake caused by fraud and
misrepresentation by the Valencias.
 The consignation made by Castro was upheld, even without prior offer or tender of
payment, under considerations of equity.
 The auction sale was declared null and void because it was held on a day that was
declared a special public holiday without the required notices being posted.
Ratio:
 The Supreme Court held that the contracts were void due to substantial mistake caused
by fraud and misrepresentation by the Valencias.
CASE SUMMARY
Parties Involved and Loan Transactions
 Maxima Castro obtained a loan from Rural Bank of Caloocan, Inc. with the
assistance of Severino Valencia.
 On the same day, the Valencia spouses also obtained a loan from the bank.
 Castro signed as a co-maker in the promissory note of the Valencia spouses.
 Both loans were secured by a real estate mortgage on Castro's property.
Allegations and Complaint
 Castro filed a complaint against the bank, claiming that the Valencias fraudulently
induced her to sign as a co-maker and to mortgage her property.
 She also deposited the amount of her personal loan with the court.
Trial Court Decision
 The trial court declared the promissory note, mortgage contract, and auction sale
null and void.
Court of Appeals Decision
 The Court of Appeals affirmed the decision of the trial court.
Supreme Court Decision
Void Contracts due to Fraud and Misrepresentation
  The Supreme Court held that the contracts were void due to fraud and
misrepresentation committed by the Valencias.
Consignation of Payment
 The court upheld Castro's consignation of payment, even without prior offer or
tender of payment, based on considerations of equity.

CASE 2
Facts:
 Defendant Brigida Marcos obtained a loan of P2,000 from plaintiff Cristina
Marcelo Vda. de Bautista and mortgaged a two-hectare portion of an unregistered
parcel of land in Tarlac to secure the loan.
 The mortgage was executed before the issuance of the patent to the mortgagor.
 Brigida Marcos filed an application for the issuance of a free patent over the land
in July 1956, which was granted on January 25, 1957.
 The patent was registered in their names on February 22, 1957.
 Vda. de Bautista filed an action for the payment of the debt or foreclosure of the
mortgage in 1959.
Issue:
 Whether a mortgagee may foreclose a mortgage on a piece of land covered by a
free patent when the mortgage was executed before the patent was issued and is
sought to be foreclosed within five years from its issuance.
Ruling:
 The Supreme Court ruled in favor of the defendants.
 The mortgage in question was deemed void and ineffective because it was
constituted before the issuance of the patent to the mortgagor.
 However, the invalidity of the mortgage contract does not invalidate the collateral
agreement whereby possession of the land mortgaged was transferred to the
mortgagee in usufruct.
 The mortgagee, being unaware of any flaw in her mode of acquisition, is
considered a possessor in good faith and is entitled to all the fruits received during
the period of her possession in good faith.
Ratio:
 The court based its ruling on the essential requirement for the validity of a
mortgage, which is that the mortgagor must be the absolute owner of the thing
mortgaged.
Summary of Case 2
Case Background and Main Question
 The case of Vda. de Bautista v. Marcos revolves around the validity of a mortgage
executed before the issuance of a patent on a piece of land.
 The main question in this case is whether a mortgagee may foreclose a mortgage
on a piece of land covered by a free patent where the mortgage was executed
before the patent was issued and is sought to be foreclosed within five years from
its issuance.
Facts of the Case
 Defendant Brigida Marcos obtained a loan from plaintiff Cristina Marcelo Vda. de
Bautista.
 To secure payment, Marcos conveyed a portion of an unregistered parcel of land
to Bautista by way of mortgage.
 The mortgage provided that it would last for three years and possession of the land
would be turned over to Bautista by way of usufruct.
 The mortgage would only be released upon payment of the principal loan.
 Subsequently, Marcos filed an application for the issuance of a free patent over the
land in question, and the patent was issued and registered in their names.
Argument and Motion to Dismiss
 Bautista filed an action for the payment of the debt or foreclosure of the mortgage
on the land.
 The defendants moved to dismiss the action, arguing that the land is covered by a
free patent and cannot be foreclosed within five years from its issuance.
Court Ruling on the Validity of the Mortgage
 The court ruled that the mortgage in question is void and ineffective because it
was constituted before the issuance of the patent.
 It is an essential requirement for the validity of a mortgage that the mortgagor be
the absolute owner of the thing mortgaged.
 The subsequent acquisition of title through the issuance of a free patent does not
validate the mortgage.
 A homestead cannot be taken for the satisfaction of debts contracted prior to the
expiration of five years from the issuance of the patent.
CASE 3
Facts:
 Vincent Dayrit, Leonila T. Sumbillo, and Reynaldo Angeles entered into a loan
and mortgage agreement with Mobil Oil Philippines, Inc.
 The agreement stated that Mobil granted a loan of P150,000 to the borrowers, who
were required to repay the loan plus 10% interest per annum for 48 months.
 To secure the loan, the borrowers transferred their properties covered by TCT No.
45169 and TCT No. 45170 to Mobil as collateral.
 The agreement also provided that in case of default, Mobil had the right to
foreclose the mortgage and the borrowers would be liable for attorney's fees and
costs of collection.
 The defendants violated the loan and mortgage agreement by failing to make the
required payments and purchase the required quantities of products.
 Mobil made a demand for payment, and Dayrit acknowledged his liability in
response.
 The trial court rendered a decision ordering the defendants to pay one-third each of
the sum of P147,434 with interest, and in default of payment, the mortgaged
properties would be sold in foreclosure.
 The defendants did not appeal the decision, and it became final and executory.
  Dayrit filed a motion to stay execution and offered to pay his one-third share with
a reasonable discount, requesting the release of the mortgage on his properties.
 The court granted a 30-day grace period for Dayrit to pay.
 Dayrit later filed another motion for an extension and to submit a compromise
agreement for the satisfaction of the judgment.
 Mobil opposed the motions and requested a writ of execution against Dayrit.
 The court denied Dayrit's motions and ruled that there was no need for an order for
the issuance of a writ of execution since it had already been ordered in a previous
order.
 Dayrit then filed a petition for certiorari with the Court of Appeals, alleging that
the trial court acted without jurisdiction or with grave abuse of discretion in
denying his motion to pay his one-third share and release the mortgage on his
properties.
 The Court of Appeals dismissed the petition, stating that there was no abuse of
discretion in ordering the execution of a final judgment.
 Dayrit filed a motion for reconsideration, which was denied.
Issue:
1. Whether the trial court acted without jurisdiction or with grave abuse of discretion
in denying Dayrit's motion to pay his one-third share of the judgment obligation.
2. Whether the Court of Appeals erred in dismissing the petition for certiorari based
on a ground that did not align with the issue raised in the petition.
3. Whether the Court of Appeals erred in denying Dayrit's motion for reconsideration
based on an alleged misapprehension of the terms of the judgment.
Ruling:
The petition is denied.
Summary
Background of the Case
 The case involves a dispute over a loan and mortgage agreement between Vincent
Dayrit and Mobil Oil Philippines, Inc.
 Dayrit, along with two other defendants, entered into a contract with Mobil Oil
Philippines, Inc. in which they agreed to repay a loan of P150,000 plus interest
over a period of 48 months.
 To secure the loan, the defendants transferred their properties to Mobil Oil
Philippines, Inc. as collateral.
Failure to Make Payments and Purchase Products
 The defendants failed to make the required payments and purchase the specified
quantities of products as stated in the agreement.
 Mobil Oil Philippines, Inc. made a demand for payment, and Dayrit acknowledged
his liability in response.
Trial Court Decision
 The trial court ordered the defendants to pay their respective shares of the loan,
with Dayrit's liability not exceeding one-third of the total obligation.
 The court also ordered the sale of the mortgaged properties to satisfy the debt.
Motion to Stay Execution and Proposed Payment
 Dayrit filed a motion to stay execution and proposed to pay his one-third share of
the debt with a reasonable discount, requesting the release of the mortgage on his
properties.
 The court granted a 30-day grace period for Dayrit to make the payment.
 Dayrit later requested a 20-day extension to pay his share and submit a
compromise agreement for the satisfaction of the judgment.
 Mobil Oil Philippines, Inc. opposed Dayrit's motion, stating that the entire debt
must be paid in order for the mortgage to be released.
Denial of Motion and Petition for Certiorari
 The court denied Dayrit's motion and ruled that there was no need to issue a writ
of execution since it had already ordered the issuance of one in a previous order.
 Dayrit filed a petition for certiorari with the Court of Appeals, alleging that the
court had acted without jurisdiction or with grave abuse of discretion in denying
his motion.
 The Court of Appeals dismissed Dayrit's petition, stating that there was no abuse
of discretion in ordering the execution of the final judgment.
Petition to the Supreme Court
 Dayrit raised several issues in his petition to the Supreme Court, including
whether the lower court had acted without jurisdiction or with grave abuse of
discretion.
 The Supreme Court noted that Dayrit's petition was filed beyond the reglementary
period and was therefore time-barred, but decided to consider the merits of the
case.
Supreme Court Decision
 The Supreme Court held that the lower court had not erred in ordering the sale of
the mortgaged properties to satisfy the entire debt.
 The court emphasized that the mortgage directly and immediately subjected the
properties to the debt, and the intention of the Loan and Mortgage Agreement was
to secure the entire loan.
Case 4
Facts:
 Plaintiff-appellant: Diosdado Yuliongsiu
 Defendant-appellee: Philippine National Bank (PNB)
 Yuliongsiu owned two vessels, M/S Surigao and M/S Don Dino, and operated the
FS-203.
 Yuliongsiu obtained a loan of P50,000 from PNB on June 30, 1947, and pledged
the vessels and his equity in the FS-203 as collateral.
 Yuliongsiu made partial payment of the loan but failed to pay the remaining
balance.
 In April 1948, PNB took physical possession of the vessels and executed a
document of sale, transferring the vessels and Yuliongsiu's equity in the FS-203 to
PNB.
  The vessels were subsequently sold to third parties.
Issue:
1. Is the pledge contract valid and does it allow PNB to take possession of the
vessels?
2. Is constructive delivery sufficient to make the pledge effective?
3. Is the private sale of the vessels by PNB to itself valid?
4. Is the price obtained at the sale unconscionable?
5. Is Yuliongsiu entitled to damages?
Ruling:
The court ruled in favor of PNB on all issues.
Ratio:
1. The pledge contract is a fact and the parties have stipulated to its validity.
Yuliongsiu is bound by this judicial admission, and the pledge contract allows
PNB to take possession of the vessels.
2. Yuliongsiu's possession of the vessels was made "subject to the order of the
pledgee," indicating that he held the pledged property as a trustee for PNB. In this
case, constructive delivery is sufficient, considering the nature of the objects
pledged.
Summary
Background and Parties Involved
 The case involves a dispute between Diosdado Yuliongsiu, the plaintiff-appellant,
and the Philippine National Bank (PNB), the defendant-appellee.
 Yuliongsiu obtained a loan of P50,000 from PNB in June 1947 and pledged two
vessels, the M/S Surigao and M/S Don Dino, as well as his equity in the FS-203,
as collateral.
Constructive Delivery and Validity of Pledge
 Yuliongsiu argues that constructive delivery is insufficient to make a pledge
effective and cites a previous ruling that requires actual delivery of the pledged
chattels.
 The court explains that the type of delivery depends on the nature and
circumstances of each case.
 In this case, since PNB had full control of the vessels through Yuliongsiu, the
delivery arrangement was deemed sufficient.
Private Sale of Vessels
 On April 6, 1948, PNB took physical possession of the vessels after Yuliongsiu
failed to pay the first promissory note.
 The bank executed a private sale of the vessels to itself for P30,042.72.
 Yuliongsiu argues that the private sale is invalid and claims that the statutory
requirements for public sales with prior notice should apply.
 The court clarifies that these requirements only apply to foreclosure of real estate
mortgages, not pledges.
 The court also notes that if the sale were private and the bank became the
purchaser, Yuliongsiu could have redeemed the property.
Unconscionable Price
 Yuliongsiu argues that the price obtained at the sale was unconscionable.
 The court states that Yuliongsiu had the opportunity to set aside the sale but did
not do so.
Case 5
Facts:
 Respondent spouses Jose P. Villanueva and Timotea P. Villanueva mortgaged
three lots to the Tarlac Branch of the Philippine National Bank to secure a loan.
 The bank petitioned the Provincial Sheriff of Tarlac to foreclose on the properties
when the respondents failed to comply with the mortgage contract.
 The lots were sold in a public auction on March 7, 1977, with Leonardo Tioseco
emerging as the highest bidder.
 The certificate of sale was registered on March 8, 1977, and Tioseco's ownership
over the properties was consolidated on March 7, 1978.
Issue:
 Did the respondents effectively exercise their right of redemption within the one-
year redemption period?
Ruling:
 The Supreme Court affirmed the lower court's ruling, allowing the respondents to
redeem the property through a court action within the one-year redemption period,
despite the lack of a formal tender of the repurchase price.
Summary
Background of the Case
 The case involves the mortgage of three lots by the respondents, Jose P.
Villanueva and Timotea P. Villanueva, to the Tarlac Branch of the Philippine
National Bank to secure a loan.
 The respondents failed to comply with the mortgage contract, leading the bank to
petition the Provincial Sheriff of Tarlac to foreclose on the properties.
 The lots were sold in a public auction on March 7, 1977, and Leonardo Tioseco
emerged as the highest bidder.
 Tioseco's ownership over the properties was consolidated, and a certificate of sale
was issued to him on March 7, 1978.
Offer to Redeem and Lawsuit
 Before March 9, 1978, the respondents visited Tioseco and offered to pay the
amount he had paid for the lots at the auction sale to redeem the properties.
 Tioseco allegedly demanded a higher redemption price, and the respondents filed a
suit on March 7, 1978, seeking to annul the sale and determine the proper
redemption amount.
Lower Court Ruling
 The lower court ruled in favor of the respondents, allowing them to redeem the
properties by paying the amount Tioseco paid at the auction sale plus interest and
other expenses.
 The Intermediate Appellate Court affirmed this decision.
Tioseco's Appeal to the Supreme Court
 Tioseco appealed to the Supreme Court, arguing that he did not demand an
excessive redemption price and that the respondents failed to comply with the
statutory requirements for legal redemption.
Supreme Court's Focus on Right of Redemption
 The Supreme Court focused on the question of whether the respondents effectively
exercised their right of redemption.
 The court cited Section 25 of the Civil Law, which grants the mortgagor the right
to redeem the property within one year from the registration of the foreclosure sale
by paying all claims of the bank against them, including costs, expenses, charges,
and accrued interests.
 The court concluded that the respondents exercised their right of redemption
effectively by filing a court action within the one-year redemption period.
CASE 6
Facts:
 Manuel R. Dulay, the petitioner, seeks to annul the order of Judge Glicerio V.
Carriaga, the respondent, which declared the redemption of several parcels of land
sold at an execution sale as null and void.
 In Civil Case No. 2152 of the Court of First Instance of Cotabato, Dulay was
ordered to pay Eusebio C. Tanghal, the private respondent, the sum of
P143,980.00.
 Seventeen parcels of land belonging to Dulay were levied upon and sold at a
public auction sale to Tanghal as the highest bidder for the sum of P82,598.00.
 Dulay redeemed eight of the levied properties by paying the prices at which they
were sold in the auction sale, amounting to P17,017.00.
 The trial court declared the redemption as null and void, stating that piece-meal
redemption is not allowed by law and that the judgment debtor should pay the
entire judgment debt and not just the purchase price.
Issue:
 Whether the amount payable for redemption of properties sold at an execution sale
is the judgment debt or the purchase price.
Ruling:
 The Supreme Court ruled in favor of the petitioner, Dulay.
 The Court held that in the redemption of properties sold at an execution sale, the
amount payable is no longer the judgment debt but the purchase price.
 The Court cited the case of Castillo vs. Nagtalon, which stated that the procedure
for redemption is to pay the purchaser the amount of his purchase, with interest,
together with the taxes paid by the purchaser after the purchase.
 The Court distinguished the case of DBP vs. Mirang, which involved the
redemption of mortgaged property sold at a foreclosure sale.
 In the present case, there is no charter that requires the payment of sums of money
other than those provided for in Section 30 of Rule 39, Revised Rules of Court.
  The Court emphasized that redemption of properties mortgaged with government
lending institutions is governed by special laws that provide for the payment of all
amounts owed by the debtor, but this special protection is not accorded to
judgment creditors in ordinary civil actions.
Summary
Case Background and Parties Involved
 The case of Dulay v. Carriaga involves the annulment of an order by Judge
Glicerio V. Carriaga.
 The petitioner is Manuel R. Dulay.
 The respondent is Eusebio C. Tanghal.
Facts of the Case
 In Civil Case No. 2152 of the Court of First Instance of Cotabato, Dulay was
ordered to pay Tanghal the sum of P143,980.00.
 Seventeen parcels of land belonging to Dulay were levied upon and sold at a
public auction to Tanghal for the sum of P82,598.00.
 Dulay redeemed eight of the levied properties by paying the prices at which they
were sold, amounting to P17,017.00, and was issued a Certificate of Redemption.
Trial Court's Decision
 Tanghal filed a motion to declare the redemption as null and void, citing the case
of Development Bank of the Philippines vs. Dionisio Mirang.
 The trial court ruled in favor of Tanghal, stating that piece-meal redemption is not
allowed by law and that the judgment debtor should pay the entire judgment debt
and not just the purchase price.
Petition for Certiorari
 Dulay filed a petition for certiorari to annul and set aside the order of the
respondent judge.
Supreme Court's Ruling
 The Supreme Court ruled in favor of Dulay, stating that in the redemption of
properties sold at an execution sale, the amount payable is no longer the judgment
debt but the purchase price.
 They cited the case of Castillo vs. Nagtalon, which explained the procedure for
redemption prescribed in Section 26, Rule 39 of the Rules of Court.
 The Court distinguished the Mirang case, which involved the redemption of
mortgaged property sold at a foreclosure sale, and explained that there is no
charter that requires the payment of sums of money other than those provided for
in Section 30 of Rule 39, (naay sugpon pero. An’t open eh)
CASE 7
Facts:
 Alpha Insurance and Surety Co., Inc. filed a foreclosure action against the Reyes
spouses and the Development Bank of the Philippines (DBP).
 The Reyes spouses executed a second mortgage in favor of Alpha Insurance to
secure a loan, while the two parcels of land were already mortgaged to DBP.
  The Reyes spouses defaulted on their loan, and Alpha Insurance paid off their
outstanding balance.
 Alpha Insurance filed a foreclosure action against the Reyes spouses and DBP.
Issue:
 Can the second mortgagee, Alpha Insurance, be favored over the first mortgagee,
DBP, in the foreclosure action?
Ruling:
 The second mortgagee cannot be favored until the obligations of the debtors with
the first mortgagee have been fully satisfied.
 Due to the lengthy duration of the case, the Court ordered the immediate sale of
the properties to pay off the debts.
 The proceeds from the sale should first be applied to the obligation with DBP, and
if there is any excess, it should be used to pay the obligation with the second
mortgagee.
 Any further excess should be given to the debtors.
Ratio:
 The obligations with the first mortgagee must be fully satisfied before favoring the
second mortgagee.
 This is based on the principle that the first mortgagee has preferential liens over
the second mortgagee.
SUMMARY
Case Background and Parties Involved
 The case involves a foreclosure action filed by Alpha Insurance and Surety Co.,
Inc. against the Reyes spouses and the Development Bank of the Philippines
(DBP).
 The Reyes spouses are the mortgagors, while DBP holds the first mortgage.
 The trial court ignored the foreclosure prayer and ordered the Reyes spouses to
pay their obligation to the second mortgagee.
Ruling on the Priority of Mortgagees
 The Supreme Court ruled that the second mortgagee cannot be favored until the
obligations of the debtors with the first mortgagee (DBP) have been fully satisfied.
 Even if DBP did not have any preferential liens, the second mortgagee cannot be
prioritized over DBP.
 This ruling ensures that the obligations to the first mortgagee are given priority
before the second mortgagee can claim any rights.
Immediate Sale of Properties
 Due to the lengthy duration of the case, the Supreme Court ordered the immediate
sale of the properties to pay off the debts.
 The proceeds from the sale would first be used to pay the obligation with DBP,
followed by the obligation with the second mortgagee.
 Any excess proceeds would be given to the debtors.
Criticism of Lengthy Duration of the Case
  The Supreme Court criticized the lengthy duration of the case and expressed
dissatisfaction with the fact that controversies of this nature should not have been
litigated.
CASE 8
Facts:
 Farin spouses executed a deed of real estate mortgage in favor of Marcelo Steel
Corporation as security for a promissory note on October 30, 1964.
 Marcelo Steel Corporation filed a petition for extrajudicial foreclosure of the
mortgage on July 24, 1965.
 The sheriff of Quezon City scheduled the foreclosure sale for August 26, 1965.
 Farins filed a petition for prohibition with the court on August 21, 1965, seeking to
permanently enjoin the foreclosure sale.
 The court issued an order commanding the sheriff and Marcelo Steel Corporation
to desist from proceeding with the sale.
 The court rendered a decision on October 3, 1970, dismissing the Farins' petition
and lifting the order of status quo.
 Farins received a copy of the decision on October 15, 1970.
 Marcelo Steel Corporation filed another petition for foreclosure on October 19,
1970, and the sheriff scheduled the sale for December 9, 1970.
 Farins filed an urgent motion to stop the sale on December 2, 1970, but the court
denied the motion.
 The sale proceeded, and Marcelo Steel Corporation acquired the properties.
 Marcelo Steel Corporation filed a petition for a writ of possession on January 12,
1971, which the court granted on February 4, 1971.
Issue:
 Whether the trial court exceeded its jurisdiction in denying the Farins' motion to
stop the foreclosure sale and in issuing the writ of possession.
Ruling:
 The trial court did exceed its jurisdiction.
Ratio:
 The trial court should have granted the Farins' motion to stop the foreclosure sale
since they had already perfected their appeal from the decision dismissing their
petition for prohibition.
 The decision in the civil case was not immediately executory as a matter of right
but only of sound judicial discretion.
 Since the prevailing party did not move for immediate execution, the trial court
could not have availed itself of its powers under the rules.
SUMMARY
Background of the Case
 The Farin spouses executed a deed of real estate mortgage in favor of Marcelo
Steel Corporation as security for a promissory note.
 Marcelo Steel Corporation filed a petition for extrajudicial foreclosure of the
mortgage.
  The Sheriff of Quezon City scheduled the foreclosure sale.
 The Farins filed a petition for prohibition with the Court of First Instance of Rizal,
seeking to permanently enjoin the sheriff from proceeding with the sale and
claiming damages.
 The court issued an order commanding the sheriff and the corporation to desist
from proceeding with the sale.
Trial Court Decision
 After trial, the court dismissed the Farins' petition and lifted the order of status
quo, allowing the sheriff to proceed with the foreclosure sale.
 The Farins received a copy of the decision and filed an appeal.
 Before the appeal could be decided, Marcelo Steel Corporation filed a motion for
the issuance of a writ of possession, which the court granted.
Court of Appeals' Ruling
 The Court of Appeals held that the trial court exceeded its jurisdiction in denying
the Farins' motion to stop the foreclosure sale.
 The Farins' remedy was a special civil action of prohibition, not an ordinary action
of injunction.
 The decision in the civil case was not immediately executory as a matter of right.
 The issuance of the writ of possession amounted to an execution of the decision,
which should have been stayed pending the appeal.
Supreme Court's Ruling
 The Supreme Court disagreed with the Court of Appeals' ruling.
CASE 9

Facts:
 The case involves a dispute over the ownership of a parcel of land in Nasipit,
Agusan del Norte.
 The land was originally covered by Original Certificate of Title (OCT) No. RO-
238(555) issued in the names of Apolonia Abao and her daughter Irenea Tolero.
 The title was fraudulently cancelled and replaced with Transfer Certificate of Title
(TCT) No. RT-476 in the name of Tolero and Nicolas Jadol.
 The land was subsequently subdivided and sold to various individuals, including
the petitioner Tiburcio Samonte.
Issue:
 Whether the cancellation of the title and subsequent transactions were fraudulent.
 Whether the action for reconveyance of the land based on fraud had prescribed.
 Whether Samonte was a buyer in good faith.
Ruling:
 The Supreme Court upheld the ruling of the Court of Appeals.
 The court declared the heirs of Abao and Tolero as co-owners of the land.
 The court ordered the cancellation of the fraudulent titles.
 The court directed the defendants, including Samonte, to vacate the premises and
pay damages.
  The court held that Samonte was not a buyer in good faith and was not entitled to
the protection of the law.
Ratio:
 The discovery of fraud in the registration of the land did not start the prescriptive
period, as the fraudulent act was only discovered during the trial.
 The action for reconveyance of the land based on fraud had not yet prescribed, as
the heirs only discovered the fraudulent act during the trial of the first case.
 Samonte was not a buyer in good faith, as he had knowledge of the fraudulent
transactions and purchased a portion of the land from the Jadol spouses when it
was still registered under the fraudulent title.
SUMMARY
Background and Introduction
 The case of Samonte v. Court of Appeals involves a dispute over a parcel of land
in Agusan del Norte, Philippines.
 The land in question is Lot No. 216, originally covered by Original Certificate of
Title (OCT) No. RO-238(555) issued in the names of Apolonia Abao and her
daughter Irenea Tolero.
 The title was fraudulently cancelled and replaced with Transfer Certificate of Title
(TCT) No. RT-476 in the name of Tolero and Nicolas Jadol.
 The land was subsequently subdivided into Lot No. 216-A and Lot No. 216-B,
with TCT No. RT-553 issued to Tiburcio Samonte for Lot No. 216-A and TCT
No. RT-554 issued to Tolero and Jadol for Lot No. 216-B.
Legal Action and Rulings
 In 1975, the heirs of Abao and Tolero filed two cases to recover Lot No. 216,
claiming that the cancellation of the original title and subsequent titles derived
from it were tainted with fraud.
 Both the trial court and the appellate court ruled in favor of the heirs, declaring the
cancellation of TCT No. RT-476 and all subsequent titles as null and void.
 The court ordered the defendants, including Samonte, to vacate the premises and
pay damages.
Prescription of Action for Reconveyance
 Samonte argued that the action for reconveyance had already prescribed, as the
cancellation of the original title and issuance of TCT No. RT-476 occurred in
1957, and the heirs only filed the cases in 1975.
 The court rejected this argument, stating that the prescriptive period should be
reckoned from the time the heirs actually discovered the fraudulent act, which was
during the trial of the first case.
 Therefore, the action for reconveyance had not yet prescribed.
Lack of Good Faith of Samonte
 The court found that Samonte was not a buyer in good faith.
 He knew that the heirs were the only surviving heirs of Tolero, yet he still bought
a portion of the land from the Jadol spouses when it was still registered under the
original title.
  The court emphasized that one who buys from a person who is not the registered
owner is not a purchaser in good faith.
CASE 10
Facts:
 Mario Valcueba filed a complaint for illegal dismissal and nonpayment of wages
against Hilario Ramirez.
 Valcueba claimed that he was hired as a mechanic by Ramirez but was not paid for
holidays and rest days, as well as the complete amount of his 13th month pay.
 Ramirez argued that Valcueba was never terminated from his employment and
instead abandoned his job.
 The Labor Arbiter ruled in favor of Ramirez, stating that there was no dismissal to
speak of in the case.
 However, the Labor Arbiter also ordered Ramirez to pay Valcueba wage
differential and 13th month pay.
Issue:
 Whether or not there was illegal dismissal and nonpayment of wages in the case.
Ruling:
 The Supreme Court upheld the dismissal of Ramirez's petition.
 The decision of the Labor Arbiter became final and executory.
 Ramirez was ordered to pay the monetary award to Valcueba.
Ratio:
 The appeal bond requirement is mandatory and failure to comply with procedural
rules warrants dismissal.
SUMMARY
Background of the Case
 The case of Ramirez v. Court of Appeals involves a complaint for illegal dismissal
and nonpayment of wages filed by Mario Valcueba against Hilario Ramirez.
 Valcueba claimed that he was hired as a mechanic by Ramirez and was not paid
for holidays and rest days, as well as the complete amount of his 13th month pay.
 Ramirez argued that Valcueba was never terminated from his employment and
instead abandoned his job.
Ruling of the Labor Arbiter
 The Labor Arbiter ruled in favor of Ramirez, stating that there was no evidence to
support Valcueba's claim of dismissal.
 However, the Labor Arbiter also ordered Ramirez to pay Valcueba wage
differentials and 13th month pay.
Appeal to the National Labor Relations Commission (NLRC)
 Ramirez filed an appeal with the NLRC, but his appeal was dismissed due to
insufficient appeal bond.
 Ramirez then filed a motion for reconsideration, which was also denied by the
NLRC.
Petition to the Court of Appeals
  Ramirez went to the Court of Appeals, but his petition was dismissed for failure to
properly verify the petition and state material dates.
 The Court of Appeals also denied Ramirez's motion for reconsideration.
Petition to the Supreme Court
 Ramirez argued in his petition to the Supreme Court that the Court of Appeals
erred in not considering the substantial compliance of his petition and that the
dismissal resolution did not resolve the legal issues raised.
 The Supreme Court upheld the dismissal of Ramirez's petition, stating that the
appeal bond is a mandatory requirement for the perfection of an appeal in cases
involving monetary awards.