Case Digest (G.R. No. 174689)
Facts:
In Lilia B. Ada, Luz B. Adanza, Flora C. Baylon, Remo Baylon, Jose Baylon, Eric Baylon, Florentino Baylon, and Ma. Ruby Baylon v. Florante Baylon (G.R. No. 182435, August 13, 2012), the petitioners are the surviving heirs of spouses Florentino and Maximina Elnas Baylon, who owned forty-three parcels of land in Negros Oriental. Upon the Spouses’ deaths (1961 and 1974), their children and subsequent heirs inherited these properties. In 1996, the petitioners sued for partition, accounting, and damages, alleging that Rita Baylon had wrongfully appropriated estate income and had refused to join in partition. In their answer, Florante (Rita’s stepson), Rita, and Panfila Gomez contended that Rita personally owned ten of the parcels and that others were owned by third parties. While the case was pending, Rita donated two contested lots (Lot 4709 and half of Lot 4706) to Florante by a July 6, 1997 deed. Rita died intestate in 2000. In 2002, the petitioners filed a supplemental pleading sCase Digest (G.R. No. 174689)
Facts:
- Background
- Spouses Florentino Baylon and Maximina Elnas Baylon died on November 7, 1961 and May 5, 1974, respectively.
- They were survived by legitimate children: Rita, Victoria (d. 1981), Dolores (d. 1976), Panfila, Ramon (d. 1989) and Lilia B. Ada.
- Victoria left one daughter, Luz B. Adanza. Ramon left one son, Florante Baylon (respondent), and second wife Flora with children Ramon Jr., Remo, Jose, Eric, Florentino and Ma. Ruby Baylon (petitioners).
- Complaint for Partition and Accounting
- On July 3, 1996, petitioners filed a Complaint for partition, accounting and damages covering 43 parcels of land in Negros Oriental inherited from Spouses Baylon.
- They alleged Rita took possession of all parcels, kept income and used it to buy Lot 4709 and half of Lot 4706 in Dumaguete City.
- Defendants (Florante, Rita, Panfila) answered they co-owned only 22 parcels; Rita exclusively owned 10; remaining parcels owned by third parties.
- Donation and Supplemental Pleading
- Rita donated Lot 4709 and half of Lot 4706 to Florante by Deed of Donation dated July 6, 1997.
- Rita died intestate and without issue on July 16, 2000.
- On February 6, 2002, petitioners filed a Supplemental Pleading praying for rescission of that donation under Article 1381(4), alleging Rita’s infirmity and lack of consent.
- Trial Court and Court of Appeals Decisions
- RTC (Oct. 20, 2005) declared co-ownership of the estate parcels, ordered their partition, rescinded the donation of Lots 4709 and 4706 for being made during pendency of litigation without approval, and denied Florante’s reconsideration (July 28, 2006).
- CA (Oct. 26, 2007) reversed the RTC’s rescission and inclusion of Lots 4709 and 4706 in Rita’s estate, remanding for determination of ownership, and denied reconsideration (Mar. 6, 2008).
Issues:
- Whether the Court of Appeals erred in ruling that the donation inter vivos of Lot No. 4709 and half of Lot No. 4706 in favor of Florante Baylon may be rescinded only after a judicial determination that those lots belonged to the estate of Spouses Baylon, under Article 1381(4) of the Civil Code.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)