Facts:

The case involves the plaintiffs Soledad Abijuela, Dorotea Lagamayo, and Reynaldo Laguidao who filed a complaint against defendants Hospicia Dolosa and Marcos Aumentado regarding two parcels of land situated in Sorsogon. The complaint sought recovery of possession of the land, damages, attorney's fees, and a declaration of ownership. The action was initiated in the Court of First Instance of Sorsogon under Civil Case No. 748. Prior to the trial’s conclusion, the defendants filed a third-party complaint against Esperanza Abijuela, the plaintiffs' relative, to which she responded. The trial court dismissed the plaintiffs' complaint, recognizing the defendants as the rightful owners of the parcels and thus entitled to their possession. The court also dissolved a preliminary injunction against the defendants and dismissed the third-party complaint with costs against the plaintiffs.

The case escalated through appellate courts, encompassing a period when the records were t

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Facts:

Background of the Case

• Plaintiffs Soledad Abijuela, Dorotea Lagamayo, and Reynaldo Laguidao initiated an action in the Court of First Instance of Sorsogon.
• Their relief sought included the recovery of possession of two parcels of land situated in Sorsogon, an award of damages and attorney’s fees, and a declaration that they were the rightful owners of these parcels as described in their amended complaint.

Involvement of Third Party and Procedural Developments

• With prior leave of the court, the defendants—Hospicia Dolosa and Marcos Aumentado—filed a third-party complaint against Esperanza Abijuela, alleging that she had sold the land to them in good faith.
• Esperanza Abijuela, as the third-party defendant, answered the complaint, which became an integral part of the proceedings.
• The trial court rendered a judgment dismissing the plaintiffs’ original complaint; it declared the defendants as the owners in possession of the two parcels, dissolved the preliminary injunction previously issued in favor of the plaintiffs, and dismissed the third-party complaint.

The Certificates of Title and the Question of Ownership

• Central to the dispute were the Original Certificates of Title Nos. 1465 and 1967, issued in 1931 in the names of spouses Jorge Abijuela and Dorotea Lagamayo.
• It was contended that when issued, Jorge Abijuela acted merely as an “encargado” or fiduciary of the properties belonging to his sister, Esperanza Abijuela.
• The appellants argued that, given his status, the certificates should not be deemed to have transferred any substantive title that would affect Esperanza Abijuela’s property rights.

Procedural History Leading to the Appeal

• The appeal process began on December 21, 1955, when the plaintiffs filed a notice of appeal with the trial court.
• In their notice, they explicitly stated that the appeal was based “on questions of law and evidence,” thereby identifying the primary legal issues while simultaneously mentioning evidentiary concerns.
• The Clerk of Court forwarded the case to the Court of Appeals on May 12, 1956, which then transmitted the records to the Supreme Court on March 10, 1958.
• The Supreme Court later noted, based on established precedents, that by indicating the appeal was on questions of law and evidence, the appellants had effectively waived their right to dispute findings of fact.

Additional Factual Findings

• Evidence showed that despite the sale of the land by Jorge Abijuela to his sister Esperanza Abijuela on July 3, 1928, he continued to reside on the property as her “encargado.”
• Subsequent events revealed that the registration of the titles as conjugal property in the names of Jorge Abijuela and Dorotea Lagamayo did not alter the underlying ownership of Esperanza Abijuela.
• The defendants later acquired possession of the properties by purchasing them from Esperanza Abijuela, culminating in further transactions and evidentiary submissions regarding the payment of fees and subsequent transfers.
• The trial records also indicated that the certificates were “rescued” and paid for well over 20 years after their original issuance, further complicating the nature of legal possession and title.

Issue:

Appellate Jurisdiction and the Scope of the Appeal

• Whether the Supreme Court had jurisdiction to review the case given that the notice of appeal raised both questions of law and evidence.
• Whether the deliberate inclusion of evidentiary issues in the notice of appeal constituted a waiver of the right to challenge factual findings made by the lower court.

Effect and Validity of the Certificates of Title

• Whether the Original Certificates of Title Nos. 1465 and 1967, issued in the name of spouses Jorge Abijuela and Dorotea Lagamayo in 1931, legally affected the property rights of Esperanza Abijuela.
• Whether the issuance of these titles to Jorge Abijuela—as merely an “encargado” or fiduciary—rendered the certificates null and without legal effect.

Impact on True Ownership

• Whether, notwithstanding the registration of the titles, the true and real ownership vested in Esperanza Abijuela remained unaffected.
• Whether the subsequent sale and possession of the properties by the defendants were legally justified and binding on all parties involved.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)