Case Digest (G.R. No. 146622) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Teodoro Acap v. Court of Appeals and Edy de los Reyes (G.R. No. 118114, December 7, 1995), the subject of dispute was Lot No. 1130, Cadastral Survey of Hinigaran, Negros Occidental, titled under OCT No. R-12179 in the names of spouses Santiago Vasquez and Lorenza Oruma. Upon their death, their son Felixberto succeeded to the property and in 1975 executed a notarized “Declaration of Heirship and Deed of Absolute Sale” in favor of Cosme Pido. Since 1960, petitioner Teodoro Acap had been leasing 9,500 square meters of this lot and paid rentals first to Pido, then to his widow Laurenciana. After Pido’s intestate death in 1981, his heirs executed a notarized “Declaration of Heirship and Waiver of Rights” adjudicating Lot 1130 to themselves and quitclaiming their shares in favor of private respondent Edy de los Reyes. Although de los Reyes never signed this document, he filed it with the Registry of Deeds as an adverse claim and announced himself as owner, demanding lease rental. A Case Digest (G.R. No. 146622) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Title and Tenancy
- Lot No. 1130, Cadastral Survey of Hinigaran, Negros Occidental (13,720 sq.m.), was covered by OCT No. R-12179 in the names of spouses Santiago Vasquez and Lorenza Oruma. Upon their deaths, their son Felixberto inherited the title.
- Since 1960, petitioner Teodoro Acap leased 9,500 sq.m. of that lot, paying rentals to Felixberto Vasquez, then to Cosme Pido (who acquired a “Declaration of Heirship and Deed of Absolute Sale” from Felixberto in 1975), and after Pido’s death, to his widow Laurenciana.
- Declaration of Heirship, Adverse Claim and Lease Dispute
- Cosme Pido died intestate in 1981. His heirs executed a notarized “Declaration of Heirship and Waiver of Rights,” adjudicating the land among themselves and quitclaiming their shares to Edy de los Reyes. De los Reyes filed it as a notice of adverse claim with the Registry of Deeds.
- De los Reyes then demanded that Acap recognize him as owner and pay annual rent of ten cavans of palay. Acap paid 1982 rent but refused from 1983 onward. A Ministry of Agrarian Reform conference in October 1983 (attended by Acap’s wife) reaffirmed Acap’s denial of De los Reyes’s claim.
- Proceedings Below
- On April 28, 1988, De los Reyes sued Acap for recovery of possession and damages for non-payment of rent. Acap maintained he did not recognize De los Reyes’s title and invoked his rights under R.A. 3844 (as amended) and P.D. 27.
- On August 20, 1991, the R.T.C. of Himamaylan ruled in favor of De los Reyes, forfeiting Acap’s preferred right under P.D. 27, ordering ejectment, and awarding damages and attorney’s fees. The Court of Appeals affirmed on May 1, 1994.
Issues:
- Whether the “Declaration of Heirship and Waiver of Rights” is a recognized mode of acquiring ownership by private respondent over Lot No. 1130.
- Whether the said document can be considered a deed of sale transferring ownership of the lot to private respondent.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)