The Estate of Pedro C. Gonzales v. The Heirs of Marcos Perez

Summary

This case involves a property ownership dispute over a portion of municipal land. Pedro Gonzales purchased lots from Marikina Municipality in 1966 and subsequently sold a portion to Marcos Perez through an unnotarized deed. After both parties died, their heirs disputed ownership. The RTC initially ruled the unnotarized sale invalid, but the Court of Appeals reversed, holding that unnotarized real property sales remain valid between parties. The Supreme Court affirmed, establishing that Pedro gained ownership through delivery in 1966 (not when formal title was issued in 1992), and that the Civil Code's form requirements under Article 1358 are for convenience, not validity. The case clarifies that municipal contracts pending gubernatorial approval are voidable (not void) until actually disapproved, and reinforces that unnotarized real property sales, while not complying with formal requirements, remain binding between contracting parties under the Civil Code.