Case Digest (G.R. No. L-14937)
Facts:
The case involves plaintiffs Magdalena Aguilor and others, who filed an appeal against defendants Florencio Balatico and Gregorio Aguilor. The appeal was made to the Supreme Court following a decision by the Court of First Instance of Cagayan, which dismissed the plaintiffs' complaint without costs. The case centers around a parcel of land measuring 36,772 square meters located in Calaoagan Bassit, Gattaran, Cagayan. The land was originally owned by Hilario Aguilor, who was married to Fausta Unday, with whom he had a daughter, Magdalena. After Fausta's death, Hilario lived with Beatriz Asuncion, although it was unclear if they were legally married. Beatriz had a child with another man, Inocencio Melchor, who died in 1945, leaving behind several children, including Juan and Pantaleon Ga.
The plaintiffs claimed to be the heirs of Hilario Aguilor and sought to repurchase the land, alleging it was mortgaged rather than sold to the defendants. The defendants contended t...
Case Digest (G.R. No. L-14937)
Facts:
Ownership and Family Background:
- Hilario Aguilor was the registered owner of a 36,772 square meter parcel of land in Calaoagan Bassit, Gattaran, Cagayan.
- He was first married to Fausta Unday, with whom he had a daughter, Magdalena Aguilor.
- After Fausta's death, Hilario lived with Beatriz Asuncion, but it was unclear whether they were legally married. Beatriz had a child, Inocencio Melchor, from a previous relationship.
- Inocencio Melchor died in 1945, leaving behind children: Juan, Pantaleon, Avelina, Ventura, Felisa, Leonora, and Benigno Ga.
Claim of Heirs:
- The plaintiffs, claiming to be heirs of Hilario Aguilor, sought to repurchase the land, alleging it was only mortgaged to the defendants, Florencio Balatico and Gregorio Aguilor.
- Plaintiffs argued that the land was cleared during Hilario’s marriage to Fausta Unday, with a larger portion cleared during his cohabitation with Beatriz Asuncion.
Defendants’ Contention:
- Defendants asserted that Hilario Aguilor sold the land to them on April 20, 1949, for P1,000 (Exhibit 1).
- They claimed that P500 of the sale price was paid to Juan Ga and Pantaleon Ga, who were allegedly authorized by their co-heirs to receive the amount.
- Defendants took possession of the land, declared it in their names, and paid taxes from 1950 to 1958.
Rebuttal by Plaintiffs:
- Plaintiffs argued that Domingo Aguilor did not thumbmark the deed of sale (Exhibit 1) and presented a written statement (Exhibit B) to support this claim.
- Juan Ga denied receiving P500 from the defendants.
Defendants’ Counter-Evidence:
- Atty. Joaquin R. Andres testified that he prepared and notarized Exhibit 1, and that both Hilario and Domingo Aguilor thumbmarked the document in his presence.
- He also stated that Domingo Aguilor was misled by Juan Ga into signing Exhibit B.
Issue:
- (Unlock)
Ruling:
- (Unlock)
Ratio:
Presumption of Regularity of Public Documents:
- Public documents, such as the deed of sale (Exhibit 1), are presumed to have been executed in accordance with the law and the parties’ agreement.
Exclusive Ownership:
- A property registered in the name of a widower belongs exclusively to him, and he has the right to sell it without the consent of other claimants.
Prohibition on Alienation Under the Public Land Act:
- The prohibition on the sale or encumbrance of homestead or free patent lands applies only within five years from the issuance of the patent. The sale in this case occurred well beyond this period.
Burden of Proof:
- The burden of proving that the transaction was a mortgage, not a sale, lies with the party making the claim. The plaintiffs failed to meet this burden.