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JurisprudenceG.R. No. 233461 -

G.R. No. 233461 - VICENTE ATLAS R. CATALAN AND MARYROSE T. DIAZ, VS. CRISTINA B. BOMBAES.G.R. No. 233681 MA. KRISTEL B. AGUIRRE, VS. CRISTINA B. BOMBAES.R E S O L U T I O N - Supreme Court E-Library

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TL;DR — Ruling

The case was docketed as CA-G.

Decision

Ruling

accordingly transferred in Catalan's name under TCT No. T-58922. [7] Then, on April 9, 2010, Aguirre offered to purchase the subject property from Catalan, who readily agreed and executed a Deed of Conditional Sale over the lot on the same day. Thereafter, they executed a Deed of Absolute Sale dated May 4, 2010 upon Aguirre's full payment of the purchase price. [8] Notably, the subject property is now registered under TCT No. 097-2010000326 in Aguirre's name. [9] In the Complaint, Bombaes alleged, among others, that Catalan coerced her to sign a simulated Deed of Absolute Sale over the subject property in his favor when she failed to settle her loan obligation. She argued that the real purpose of the simulated sale was for Catalan to mortgage the lot to a lending institution and apply the proceeds thereof to her unpaid loan obligation. However, instead of mortgaging the subject property, Catalan sold the lot to Aguirre. [10] In his defense, Catalan countered that when Bombaes failed to pay her outstanding debt, he told the latter that he might sell or mortgage the subject property to a lending institution because he needed the money. He and Bombaes then executed a Deed of Assignment so that the latter would be able to redeem the property should he decide to mortgage the property to a lending institution. Catalan further averred that aside from the Deed of Absolute Sale dated October 19, 2009, Bombaes also signed an Acknowledgment Receipt and a Deed of Confirmation of the sale of the lot to him. [11] For her part, Aguirre contended that when she entered into the Deed of Conditional Sale dated April 9, 2010 with Catalan, she had no prior notice that Bombaes, or any other person, had a right or interest over the subject property. Thus, Aguirre asserted that she was an innocent purchaser in good faith and for value given her full reliance on Catalan's clean title over the lot at the time of execution of the Deed of Absolute Sale dated May 4, 2010. [12] The Ruling of the RTC In the Decision [13] dated October 24, 2012, the RTC dismissed the Complaint for lack of merit and awarded moral damages to Catalan in the amount of PHP 100,000.00. [14] The RTC ruled that Aguirre was a buyer in good faith and for value considering that Catalan was already the owner of the subject property when she purchased the lot as evidenced by TCT No. T-58922, which had no adverse claim or any lis pendens annotated thereon at the time of the sale. [15] Aggrieved, Bombaes appealed before the CA. [16] The case was docketed as CA-G.R. CV No. 04775. The Ruling of the CA In the Decision [17] dated May 31, 2016, the CA affirmed the RTC Decision but it deleted the moral damages awarded to Catalan for lack of sufficient basis. [18] The CA upheld the RTC' s finding that Aguirre was an innocent purchaser in good faith and for value as she merely relied on the correctness of Catalan's clean title over the subject property. It also ruled that Bombaes failed to establish that Aguirre had