Case Review: Pasco vs Cuenca

Case Overview

• The Petition for Review on Certiorari involves Myrna C. Pasco (petitioner) against Isabel Cuenca, Romeo M. Ytang, Jr., and Esther C. Ytang (respondents).
• The case number is G.R. No. 214319, with a decision rendered on November 04, 2020.

Background of the Dispute

• The controversy centers on Lot No. 38-B in Katipunan, Zamboanga del Norte, measuring 336 square meters.
• Originally registered under spouses Antonio Baguispas and Isabel Cuenca-Baguispas (TCT No. T-12461).
• Myrna Pasco filed a complaint on September 9, 1999, for annulment of TCT, deed of sale, recovery of ownership, and damages.

Claims by Myrna Pasco

• In June 1986, the Spouses Baguispas offered to sell Lot No. 38-B to Pasco for ₱50,000, and they executed a notarized Deed of Sale on July 1, 1986.
• After Antonio's death in March 1987, Isabel executed an affidavit of self-adjudication and transferred the title to her name without Pasco's knowledge.
• Isabel sold the property to the Spouses Ytang, registering it under TCT No. T-62536.

Legal Action and Respondents' Defense

• Pasco contended TCT No. T-62536 was spurious and sought its cancellation along with the affidavit and deed of sale as null and void.
• Respondents claimed the sale to Pasco was fictitious and intended only to secure a loan with the Social Security System.
• They alleged that Isabel later requested Pasco to execute a deed of conveyance, which Pasco refused.

Ruling of the Regional Trial Court (RTC)

• On May 31, 2010, the RTC ruled in favor of Pasco, declaring TCT No. T-62536 and the subsequent Deed of Sale as null and void.
• Courts recognized Pasco as the legitimate owner of Lot 38-B and ordered the reinstatement of TCT No. T-12461 under the original owners.

Key Legal Principles

• The case emphasizes the importance of lawful ownership and genuine consideration in property transactions.
• The ruling highlights the legal consequences of self-adjudication without proper authority or knowledge of interested parties.