Case Digest (G.R. No. L-14530)
Facts:
The case of Leona Aglibot, et al. vs. Andrea Acay Manalac, et al. (G.R. No. L-14530) was decided by the Supreme Court of the Philippines on April 25, 1962. The plaintiffs, Leona and Evarista Aglibot, initiated Civil Case No. 1482 in the Court of First Instance of Zambales on July 31, 1952, seeking to recover ownership and possession of a parcel of land located in barrio Namanaan, Municipality of San Antonio, Zambales, from the defendants, Andrea Acay Manalac and her children—Ramona, Gregorio, Felix, Angela, Juanita, and Purisima Manalac. The plaintiffs claimed that they inherited the property from their deceased niece, Juliana Manalac. They alleged that after the death of Anacleto Manalac, Juliana's father, the defendants unlawfully took possession of the property, claimed it as their own, and appropriated the annual harvest of palay, which amounted to 30 cavanes. Despite demands for the return of the property, the defendants refused to surrender it.
In their answer, t...
Case Digest (G.R. No. L-14530)
Facts:
Ownership and Inheritance Dispute
- Leona and Evarista Aglibot filed a case in the Court of First Instance of Zambales on July 31, 1952, to recover ownership and possession of a parcel of land in barrio Namanaan, San Antonio, Zambales.
- The land was inherited by the Aglibots from their deceased niece, Juliana Manalac.
- The defendants, Andrea Acay Manalac and her children, took possession of the land after the death of Anacleto Manalac (father of Juliana) and claimed it as their own, harvesting 30 cavanes of palay annually.
Defendants' Claims
- The defendants argued that the land was purchased by Anacleto Manalac and his first wife, Maria Aglibot, for P1,000. Only P300 was paid during Maria's lifetime, and the remaining P700 was paid during Anacleto's marriage to Andrea Acay.
- Juliana Manalac, the only child of Anacleto and Maria, died in 1920, and Anacleto died in 1942. Upon Anacleto's death, Andrea Acay and her children claimed the land as his legal heirs.
Lower Court Decision
- The lower court ruled that the plaintiffs (Aglibots) were entitled to one-half of the land covered by Original Certificate of Title No. 10.
- The defendants were ordered to deliver possession of the one-half portion to the plaintiffs and to pay 15 cavanes of palay yearly or its equivalent value (P10 per cavan) from the date of the filing of the complaint.
Evidence Presented
- The land originally belonged to the conjugal partnership of Anacleto Manalac and Maria Aglibot.
- Juliana Manalac inherited one-half of the land upon Maria's death in 1906, and Anacleto inherited the other half.
- Upon Juliana's death in 1920, Anacleto inherited her share. After Anacleto's death in 1942, Andrea Acay and her children took possession of the land.
Summary Partition Proceedings
- On May 18, 1951, the Aglibots filed a petition for the summary partition of Juliana Manalac's properties. The court declared them as the only heirs within the third degree of Juliana and entitled to one-half of the land.
Issue:
- Who is entitled to the land inherited by Anacleto Manalac from his daughter, Juliana, as between the Aglibots (sisters of Maria Aglibot) and Andrea Acay and her children?
- Whether the lower court erred in ordering the defendants to deliver 15 cavanes of palay yearly or its equivalent value.
- Whether the lower court should have ordered the plaintiffs to refund 50% of the annual realty tax paid on the property.
Ruling:
- The Supreme Court affirmed the lower court's decision with modifications.
- The land is reservable property under Article 891 of the New Civil Code, and Anacleto Manalac was obligated to reserve the portion inherited from Juliana for the benefit of the Aglibots.
- The court ruled that only Andrea Acay, as the surviving spouse, should be liable for delivering 15 cavanes of palay yearly or its equivalent value from the date of the filing of the complaint.
- The claim for a refund of 50% of the annual realty tax was dismissed, as it was raised for the first time on appeal.
Ratio:
- Reservable Property: The land inherited by Anacleto Manalac from his daughter, Juliana, is reservable property under Article 891 of the New Civil Code. The Aglibots, as relatives within the third degree on the maternal side, are entitled to the reserved portion.
- Liability for Produce: Only Andrea Acay, as the surviving spouse, should be liable for delivering the annual share of palay, as she was the one in possession of the land and receiving its produce.
- Realty Tax Refund: Claims not raised in the lower court cannot be entertained on appeal.