Case Digest (G.R. No. 156310)
Facts:
The case involves Xerxes A. Abadiano (petitioner) against spouses Jesus and Lolita Martir (respondents). The dispute centers on a parcel of land identified as Lot No. 1318 of the Kabankalan Cadastre, which spans 34,281 square meters and is covered by Original Certificate of Title (OCT) No. 20461, issued on November 19, 1923, in the names of Inocentes BaAres and Feliciana Villanueva. Prior to the issuance of this title, an Agreement of Partition was executed on June 1, 1922, dividing Lot No. 1318 into three portions among the heirs of Inocentes and Feliciana. The partition was formalized in a Deed of Partition, which was notarized the following day.
In 1939, David Abadiano, who was absent during the partition, executed a Deed of Confirmation acknowledging the partition. The original title was reconstituted in 1962, and a new title, Transfer Certificate of Title (TCT) No. T-31862, was issued in the names of Dr. Leopoldo BaAres, Amando BaAres, and Ramon and David Abadiano. Th...
Case Digest (G.R. No. 156310)
Facts:
Background of the Property
- Lot No. 1318 of the Kabankalan Cadastre, consisting of 34,281 square meters, was originally covered by Original Certificate of Title (OCT) No. 20461, issued on November 19, 1923, in the names of spouses Inocentes Bañares and Feliciana Villanueva.
- Before the issuance of OCT No. 20461, an Agreement of Partition dated June 1, 1922, was executed by Inocentes Bañares and the heirs of Feliciana Villanueva, dividing Lot No. 1318 into three portions:
- Lot No. 1318-A (14,976 sq m) to Demetrio Bañares.
- Lot No. 1318-B (10,125 sq m) to Ramon and David Abadiano (grandchildren of Inocentes and Feliciana).
- Lot No. 1318-C (10,180 sq m) to Amando Bañares.
Subsequent Transactions
- On September 30, 1939, David Abadiano executed a Deed of Confirmation, ratifying the Agreement of Partition.
- OCT No. 20461 was reconstituted on February 15, 1962, and OCT No. RO-8211 (20461) was issued, still in the names of Inocentes Bañares and Feliciana Villanueva, with the Agreement of Partition and Deed of Confirmation annotated at the back.
- On June 14, 1957, Demetrio Bañares sold his share (Lot No. 1318-A) to his son, Leopoldo Bañares, which was also annotated on the title.
- On February 21, 1962, Leopoldo Bañares filed a petition for the confirmation of the Agreement of Partition, Deed of Confirmation, and Deed of Sale, leading to the cancellation of OCT No. RO-8211 (20461) and the issuance of Transfer Certificate of Title (TCT) No. T-31862 in the names of Leopoldo Bañares, Amando Bañares, and Ramon and David Abadiano.
Dispute Over Ownership
- Respondents (spouses Jesus and Lolita Martir) claimed that Ramon Abadiano, acting for himself and David Abadiano, sold their share (Lot No. 1318-C) to Victor Garde on June 3, 1922, evidenced by a Compra Y Venta document. This sale was allegedly affirmed by David Abadiano on September 30, 1939.
- The heirs of Victor Garde sold their rights to Jose Garde on December 29, 1961, who later sold the property to Lolita Martir in 1979.
- Respondents alleged continuous possession of the property since the sale to Victor Garde.
- In 1982, Roberto Abadiano (son of Ramon) entered the property and harvested sugarcane, leading to a legal dispute.
Legal Proceedings
- Respondents filed an action for quieting of title and/or recovery of possession against Roberto Abadiano, Faustino Montaño, and Quirico Mandaguit. Petitioner Xerxes Abadiano intervened, claiming that the sale to Victor Garde never occurred.
- The trial court ruled in favor of respondents, declaring them the owners of Lots 1318-B and 1318-C and ordering the cancellation of TCT No. T-31862. The Court of Appeals affirmed the decision.
Issue:
- Whether the Compra Y Venta document presented by respondents is genuine and valid.
- Whether petitioner Xerxes Abadiano is guilty of laches for failing to assert his claim over the property.
- Whether respondents are entitled to damages for the alleged unauthorized use of the property.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)