Josefina v. Gil

Summary

This case involves a property sale dispute where Josefina Palon sold undivided portions of her 200 sq.m. lot to three buyer couples through separate agreements called 'Buod ng Kasunduan.' Despite full payment by all buyers totaling P117,500 and their compliance with survey and titling requirements, Josefina refused to surrender her reconstituted title for subdivision and issuance of separate titles to buyers. The Regional Trial Court and Court of Appeals both found Josefina acted in bad faith, violating her obligations under Articles 1495 and 1497 of the Civil Code to deliver proper title documents. The Supreme Court dismissed Josefina's certiorari petition, emphasizing that the case involved factual issues already determined by lower courts and that certiorari appeals are limited to questions of law. The decision reinforced sellers' obligations in property transactions and the finality of concurrent factual findings by trial and appellate courts.