Heirs of San Miguel vs Court of Appeals | Sept 5, 2001 | J.

Pardo
Theres land in Cavite originally claimed by the Ps predecessor-ininterest, Severina San Miguel. Without her knowledge, Dominador
managed to divide the land into 3 lots and he filed with the CFI of
Cavite to issue titles for them over Lot 1 and 2, which was granted.
Severina filed with CFI a petition for review of this decision because
she said that the land registration proceedings made by Dominador
were fraudulently hidden from her. The court found for her and
declared the original certificate of title for Dominador null and void.
TC issued an order in favor of Severinas heirs, but the writ was
returned unsatisfied several times.
Severinas heirs decided to not pursue the writs of possession and
demolition, and entered into a compromise with Dominador et. al.
According to the compromise, Severinas heirs were to sell the lots to
Dominador for 1.5 million with the delivery of the TCT, conditioned
upon the purchase of another lot which wasnt titled yet at an
additional sum of 300k.
Dominador did not pay 300k but they expected that the TCT should be
delivered to them. Their reason is that Severinas heirs did not present
any proof of ownership over the untitled parcel of land (Lot 3).
Apparently, that part of the land is declared in the name of a 3rd party.
Severinas heirs said that Dominador said in their kasunduan that they
owned that land, dispensing with the requirement that the heirs
produce actual proof of title over it. Since Dominador hasnt paid the
300k, then they were justified in withholding the TCT.
TC heirs of Severina were ordered to surrender the TCT to heirs of
Dominador
CA affirmed decision of TC
Issue: W/N Dominador et. al. may be compelled to pay the 300k as
agreed upon in the kasunduan as a pre-requisite for the release of TCT
despite Severinas heirs lack o evidence of ownership over the parcel
of land contested.
Holding: No. Under the facts of the case, Severinas heirs are not in a
position to transfer title. No proof of ownership in favor of Severinas
heirs. To insist that Dominador pay the price under such circumstances
would result in the Severina heirs unjust enrichment.