Heirs of Aquilino Ramos v. Prosalita Bagares

Summary

The Supreme Court denied consolidated petitions challenging the nullity of a tampered deed of sale involving Lot No. 12020 in Misamis Oriental. Respondents purchased land from Basilia Galarrita-Naguita, while Aquilino Ramos allegedly tampered a deed of sale to secure a free patent over the same property. Both the RTC and CA found the deed void based on DENR findings and Aquilino's judicial admission of tampering. The SC affirmed, rejecting petitioners' claims of acquisitive prescription (insufficient 30-year period) and good faith buyer status (inapplicable to unregistered land). The Court emphasized that factual determinations are beyond Rule 45 review and noted procedural defects in the petitions. However, it deleted the attorney's fees award for lack of proper legal justification, reinforcing that such awards require clear factual and legal basis under Article 2208 of the Civil Code.