Case Digest (G.R. No. 161916) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Arnelito Adlawan vs. Emeterio M. Adlawan and Narcisa M. Adlawan (G.R. No. 161916, January 20, 2006), petitioner Arnelito Adlawan filed an unlawful detainer suit on August 9, 2000, against respondents Emeterio and Narcisa Adlawan over Lot 7226, covered by TCT No. 8842 in Barrio Lipata, Minglanilla, Cebu, which was alleged to belong to his late father, Dominador Adlawan, who died intestate on May 28, 1987. Petitioner asserted that as Dominador’s acknowledged illegitimate son and sole heir he executed an affidavit of self-adjudication over the lot and house thereon, and permitted respondents—his father’s siblings—to occupy the property on the condition that they vacate upon his demand. Respondents, aged 59 and 70, countered that the property was ancestral, having been registered in their father Ramon Adlawan’s name in 1962 via a simulated sale to Dominador solely to secure a loan, and that they have continuously possessed the lot since birth. They further challenged the authenti Case Digest (G.R. No. 161916) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background of Dispute
- Property involved: Lot 7226 and an ancestral house in Barrio Lipata, Minglanilla, Cebu, covered by Transfer Certificate of Title No. 8842, originally registered in the name of the late Dominador Adlawan.
- Petitioner Arnelito Adlawan, born April 10, 1967, claims to be the acknowledged illegitimate son and sole heir of Dominador; executed an affidavit of self-adjudication over Lot 7226.
- Occupancy History and Allegations
- Out of “respect and generosity,” petitioner allowed respondents Emeterio (aged 59) and Narcisa (aged 70) Adlawan—siblings of Dominador—to occupy the property, with the verbal condition they would vacate upon his need.
- Petitioner’s demands to vacate (January 1999; demand letter dated August 2, 2000) were refused; respondents instead filed a quieting‐of‐title action (RTC Civil Case No. CEB-23205).
- Respondents deny petitioner’s filiation claim, assert continuous occupancy since birth, and maintain the lot was originally ancestral property of their parents, Ramon and Oligia MaAacap Adlawan, who in 1962 executed a simulated deed of sale in favor of Dominador to secure a loan.
- Procedural History
- MTC of Minglanilla (Civil Case No. 392): on February 12, 2002, dismissed petitioner’s unlawful detainer suit for failure to prove filiation and to settle Dominador’s estate as conditions precedent.
- RTC of Cebu City (Branch 7, Civil Case No. CEB-27806): on September 13, 2002, reversed the MTC, ruling Dominador’s title cannot be collaterally attacked; ordered respondents to restore possession and pay P500/month from August 2000; granted then recalled execution pending appeal.
- Court of Appeals (CA-G.R. SP No. 74921): on September 23, 2003, set aside the RTC decision and reinstated the MTC dismissal; held that petitioner and the heirs of Dominador’s wife (Graciana) are co-owners and that petitioner cannot sue alone as sole owner; denied reconsideration on January 8, 2004.
Issues:
- Main Issue
- Whether petitioner, claiming to be the sole heir of Dominador, has the authority and legal personality to institute an ejectment (unlawful detainer) suit in his name alone.
- Subsidiary Issue
- Whether the co-ownership rules under Article 487 of the Civil Code allow a co-owner to file an ejectment suit for his exclusive benefit without joining other co-owners.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)