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G.R. No. 207051. December 01, 2021



Modesto owned an unregistered land. Modesto executed a written agreement conveying portions of the subject property to three individuals namely Jularbal, Catbagen and Dongpaen. Later, on various dates, a series of sale transactions occurred among Modesto, Dongpaen, and Ricardo for the sale of Lots 1 and 2 to Ricardo. Pursuant to an arrangement with Modesto and his son, Lorenzo, who offered to cultivate Ricardo's portion of the subject property, Ricardo saw no need to occupy Lots 1 and 2, and simply allowed Lorenzo's possession thereof.  Later, upon learning that petitioners had attempted to sell even his portion of the subject property, Ricardo began resorting to administrative remedies. Consequently, Ricardo filed a Civil Case complaint for Partition of Property and Damages. The MCTC ruled in favor of Ricardo. The RTC reversed the MCTC decision. The CA affirmed the MCTC ruling.


Whether the sale transactions among Modesto, Dongpaen, and Ricardo, covered by three Deeds of Sales, validly conveyed to Ricardo Lots 1 and 2 of the subject property.


Yes. The SC held that the series of transfers among Modesto, Dongpaen and Ricardo were valid conveyances; the deeds of sale were fully executed by the parties. The agreement is not purely a sales contract; it is an innominate contract reflecting a sales contract, a contract of agency to sell the subject property; and contract to transfer ownership of property in exchange for services. Article 1483 of the Civil Code states that "subject to the provisions of the Statute of Frauds and of any other applicable statute, a contract of sale may be made in writing, or by word of mouth, or partly in writing and partly by word of mouth or may be inferred from the conduct of the parties."
The Agreement between Modesto, as seller on one hand, and three individuals, as buyers, on the other hand, contained all the essential terms of the agreement between the parties. More importantly, all the requisites of a contract are reflected therein: (a) consent of the parties; (b) subject matter of the contract; and (c) consideration.

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