1. Cecilio Claudel acquired a lot from the Bureau of Lands in 1922 and paid taxes on it until his death in 1937, after which his family continued paying taxes.
2. In 1976, Cecilio's siblings filed a case claiming that their parents had purchased portions of the lot from Cecilio in 1930 for 30 pesos.
3. The Supreme Court ruled that the alleged 1930 oral sale was unenforceable under the Statute of Frauds, as an oral contract for the sale of land cannot be proven or enforced against third parties. Additionally, the siblings' claim had prescribed as more than six years had passed since the alleged right of action in 1930.
1. Cecilio Claudel acquired a lot from the Bureau of Lands in 1922 and paid taxes on it until his death in 1937, after which his family continued paying taxes.
2. In 1976, Cecilio's siblings filed a case claiming that their parents had purchased portions of the lot from Cecilio in 1930 for 30 pesos.
3. The Supreme Court ruled that the alleged 1930 oral sale was unenforceable under the Statute of Frauds, as an oral contract for the sale of land cannot be proven or enforced against third parties. Additionally, the siblings' claim had prescribed as more than six years had passed since the alleged right of action in 1930.
1. Cecilio Claudel acquired a lot from the Bureau of Lands in 1922 and paid taxes on it until his death in 1937, after which his family continued paying taxes.
2. In 1976, Cecilio's siblings filed a case claiming that their parents had purchased portions of the lot from Cecilio in 1930 for 30 pesos.
3. The Supreme Court ruled that the alleged 1930 oral sale was unenforceable under the Statute of Frauds, as an oral contract for the sale of land cannot be proven or enforced against third parties. Additionally, the siblings' claim had prescribed as more than six years had passed since the alleged right of action in 1930.
1. Cecilio Claudel acquired a lot from the Bureau of Lands in 1922 and paid taxes on it until his death in 1937, after which his family continued paying taxes.
2. In 1976, Cecilio's siblings filed a case claiming that their parents had purchased portions of the lot from Cecilio in 1930 for 30 pesos.
3. The Supreme Court ruled that the alleged 1930 oral sale was unenforceable under the Statute of Frauds, as an oral contract for the sale of land cannot be proven or enforced against third parties. Additionally, the siblings' claim had prescribed as more than six years had passed since the alleged right of action in 1930.
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G.R. No.
85240 July 12, 1991
HEIRS OF CECILIO (also known as BASILIO) CLAUDEL, namely, MODESTA
CLAUDEL, LORETA HERRERA, JOSE CLAUDEL, BENJAMIN CLAUDEL, PACITA CLAUDEL, CARMELITA CLAUDEL, MARIO CLAUDEL, ROBERTO CLAUDEL, LEONARDO CLAUDEL, ARSENIA VILLALON, PERPETUA CLAUDEL and FELISA CLAUDEL, petitioners, vs. HON. COURT OF APPEALS, HEIRS OF MACARIO, ESPERIDIONA, RAYMUNDA and CELESTINA, all surnamed CLAUDEL, respondents.
105. HEIRS OF CLAUDEL VS. COURT OF APPEALS
FACTS:
1… On December 28, 1922, Basilio also known as "Cecilio" Claudel, acquired from the Bureau of Lands a Lot.
2. He declared the lot in his name, and he dutifully paid the real estate taxes thereon until his death in 1937. Thereafter, his widow "Basilia" and later, her son Jose, one of the herein petitioners, paid the taxes.
3. The same piece of land purchased by Cecilio would, however, become the subject of protracted litigation thirty-nine years after his death.
4. Two branches of Cecilio's family contested the ownership over the land-on one hand the children of Cecilio, and their children and descendants, now the herein petitioners (hereinafter referred to as HEIRS OF CECILIO),
5. On the other, the brother and sisters of Cecilio, and their children and descendants, now the herein private respondents (hereinafter referred to as SIBLINGS OF CECILIO).
6. In 1972, the HEIRS OF CECILIO partitioned this lot among themselves and obtained the corresponding Transfer Certificates of Title on their shares.
7. Four years later, on December 7, 1976, private respondents SIBLINGS OF
CECILIO, filed Civil Case a "Complaint for Cancellation of Titles and Reconveyance with Damages," alleging that 46 years earlier, or sometime in 1930, their parents had purchased from the late Cecilio Claudel several portions of Lot for the sum of P30.00.
8. They admitted that the transaction was verbal. However, as proof of the sale, the SIBLINGS OF CECILIO presented a subdivision plan of the said land, dated March 25, 1930, indicating the portions allegedly sold to the SIBLINGS OF CECILIO.
LEGAL ISSUE: Whether a contract of sale of land may be proven orally; and whether the prescriptive period for filing an action for cancellation of titles and reconveyance with damages should be counted from the allege sale upon which they claim their ownership in 1930 or from the date of the issuance of the titles sought to be cancelled in favour of the heirs in 1976. RULING:
1… The Supreme Court held that a sale of land, once consummated, is valid regardless of the form it may have been entered into. For nowhere does law or jurisprudence prescribe that the contract of sale be put in writing before such contract can validly cede or transmit rights over a certain real property between the parties themselves. 2. However, in the event that a third party, as in this case, disputes the ownership of the property, the person against whom that claim is brought cannot present any proof of such sale and hence has no means to enforce the contract. Thus the Statute of Frauds was precisely devised to protect the parties in a contract of sale of real property so that no such contract is enforceable unless certain requisites, for purposes of proof, are met.
3. The provisions of the Statute of Frauds pertinent to the present controversy,
state:
Art. 1403 (Civil Code). The following contracts are unenforceable, unless they are ratified:
2) Those that do not comply with the Statute of Frauds as set forth in this number. In the following cases, an agreement hereafter made shall be unenforceable by action unless the same, or some note or memorandum thereof, be in writing, and subscribed by the party charged, or by his agent; evidence, therefore, of the agreement cannot be received without the writing, or a secondary evidence of its contents:
e) An agreement for the leasing for a longer period than one year, or for the sale of real property or of an interest therein;
4. The purpose of the Statute of Frauds is to prevent fraud and perjury in the enforcement of obligations depending for their evidence upon the unassisted memory of witnesses by requiring certain enumerated contracts and transactions to be evidenced in Writing.
5. Therefore, except under the conditions provided by the Statute of Frauds, the existence of the contract of sale made by Cecilio with his siblings cannot be proved.
THEREFORE THE CONTRACT VERBALLY MADE IS UNENFORCEALBLE UNDER
THE STATUTE OF FRAUD.
6. On the second issue, the belated claim of the SIBLINGS OF CECILIO who filed a complaint in court only in 1976 to enforce a light acquired allegedly as early as 1930, is difficult to comprehend.
7. The Civil Code states: The following actions must be commenced within six years: (1) Upon an oral contract. If the parties SIBLINGS OF CECILIO had allegedly derived their right of action from the oral purchase made by their parents in 1930, then the action filed in 1976 would have clearly prescribed. More than six years had lapsed.
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