Natividad P. Nazareno v. Court of Appeals

Summary

The Supreme Court affirmed lower courts' decisions declaring void two deeds of sale involving six lots in Quezon City within the Nazareno family. The case originated when Romeo Nazareno challenged the validity of a 1970 deed transferring properties from parents Maximino Sr. and Aurea to sister Natividad, and a subsequent 1982 sale from Natividad to brother Maximino Jr. The courts found both transactions were simulated without actual consideration, executed to avoid inheritance taxes. Despite the documents being notarized, Romeo's credible testimony about the family's practice of fictitious sales overcame the presumption of validity. The Court recognized an implied trust favoring Natividad for her siblings' benefit and applied succession law principles requiring collation of gratuitous transfers. The decision restored the properties to the estate except for lots validly sold to innocent third-party purchasers.