Milagros de Belen Vda. de Cabalu v. Sps. Renato Tabu

Summary

This case involves a property ownership dispute over a 9,000 square meter lot originally owned by Faustina Maslum. The main issue was the validity of two deeds of sale executed by Domingo Laxamana - one in 1975 to Laureano Cabalu and another in 1996 to Renato Tabu. The Supreme Court declared both sales null and void. The 1975 sale was invalid because Domingo was not yet the owner of the property at that time, having only an inchoate hereditary right until the 1994 partition, and the deed was found to be simulated with discrepancies in the notarization. The 1996 sale was void because it was executed two months after Domingo's death, violating the principle that valid contracts require parties with legal capacity at the time of execution. The Court applied Article 1347 of the Civil Code prohibiting contracts on future inheritance and emphasized that death terminates contractual capacity. The decision restored Domingo's title subject to partition by his lawful heirs while canceling all derivative titles obtained through the invalid sales.