Case Digest (G.R. No. L-44546) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Rustico Adille v. Court of Appeals, the petition arises from a dispute over Lot 14694 of the Cadastral Survey of Albay in Legazpi City, comprising some 11,325 square meters. The property originally belonged to Felisa Alzul, who first married Bernabe Adille and bore one child, Rustico Adille (petitioner), and later married Procopio Asejo, by whom she had five children—Emeteria, Teodorica, Domingo, Josefa and Santiago Asejo (private respondents). In 1939, Felisa sold the land under a pacto de retro to third parties with a three-year period to repurchase. She died in 1942 without redeeming, and during the redemption period Rustico alone redeemed the entire tract, shouldering all expenses. He then executed an extrajudicial settlement affidavit representing himself as the sole heir, secured Torrens Certificate of Title No. 21137 in his name in 1955, and thus held himself out as absolute owner. After failed compromise talks, the Asejo siblings filed a complaint for partition with a Case Digest (G.R. No. L-44546) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Land and Ownership History
- The subject is Lot 14694 of the Cadastral Survey of Albay (11,325 sqm.) in Legaspi City, originally the private property of Felisa Alzul.
- Felisa married first Bernabe Adille (issue: Rustico Adille) and second Procopio Asejo (issue: Emeteria, Teodorica, Domingo, Josefa, Santiago Asejo).
- Sale in Pacto de Retro and Redemption
- In 1939 Felisa sold the property in pacto de retro to third parties, with a three-year period to redeem.
- Felisa died in 1942 without redeeming; during redemption period, Rustico alone redeemed the entire property and executed an extrajudicial settlement as sole heir.
- Title Transfer and Prior Proceedings
- In 1955 OCT No. 21137 (in Felisa’s name) was transferred to Rustico Adille alone.
- Plaintiffs (the Asejo siblings) filed for partition with accounting; Rustico counterclaimed for Emeteria’s ejectment.
- Trial court dismissed plaintiffs’ complaint, declared Rustico absolute owner, and ordered Emeteria to vacate.
- The Court of Appeals reversed, ruling for the plaintiffs-appellants; Rustico then elevated the case to the Supreme Court.
Issues:
- Whether a co-owner who redeems the entire property in a pacto de retro acquires exclusive ownership and terminates the state of co-ownership.
- Whether the petitioner’s sole registration of Torrens title and possession operate as notice of repudiation and give rise to acquisitive prescription.
- Whether fraud in the extrajudicial settlement and registration creates an implied trust in favor of the other co-owners.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)