John Lawrence Sia v. Camilo Parrilla

Summary

This case involves a property mortgage dispute where John Lawrence Sia lent P1,000,000.00 to Camilo Parrilla, secured by a mortgage over property owned by Camilo's wife Rosalinda. However, Rosalinda had already died in 1998, three years before the mortgage was executed in 2001. Her heirs challenged the validity of the mortgage and subsequent foreclosure proceedings. All three levels of courts unanimously ruled that the mortgage was null and void ab initio under Article 2085 of the Civil Code, which requires the mortgagor to be the absolute owner of the mortgaged property. The Supreme Court affirmed the nullification of Sia's title and ordered reconveyance to Rosalinda's heirs, while modifying the interest rate from 12% to 6% per annum. The case establishes that a mortgage executed by a non-owner over property belonging to a deceased person is void from its inception.