Case Digest (G.R. No. 244542) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
Petitioners Ma. Concepcion Alferez, Antonio S. Alferez, and Esperanza Alferez Evans are the children and compulsory heirs of the late Federico J. Alferez, who died intestate on September 23, 1980, leaving a surviving spouse, Teodora, and considerable real properties in Goma and Matti, Digos City, covered by various Original and Transfer Certificates of Title. On October 25, 1980, Ma. Concepcion filed a Petition for Issuance of Letters of Administration before the Court of First Instance (CFI), Branch 5, Davao del Sur (Special Proceedings No. 437), and was appointed administratrix on January 16, 1981. An extrajudicial settlement with donation executed on January 15, 1982 among Teodora and the heirs allocated each of the three principal parcels of land to one of the petitioners. To satisfy the decedent’s outstanding bank obligations, Ma. Concepcion, with Special Powers of Attorney from Antonio and Esperanza, secured an order on August 29, 1985 authorizing the sale of the three par Case Digest (G.R. No. 244542) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Death of Decedent and Estate Proceedings
- Federico J. Alferez died intestate on September 23, 1980, survived by spouse Teodora and children Ma. Concepcion, Antonio, and Esperanza.
- Half of the conjugal partnership estate comprised five parcels of land in Goma and Matti, Digos City, Davao del Sur.
- Petition for Letters of Administration filed October 25, 1980 (SP No. 437, CFI Branch 5); Letters issued January 16, 1981 appointing Ma. Concepcion administratrix.
- Extrajudicial Settlement and Authority to Sell
- Extrajudicial Settlement with Donation executed January 15, 1982: Teodora donated her half-shares to Ma. Concepcion, Antonio, and Esperanza; petitioners waived specific interests in favor of each other.
- Urgent motion to sell estate properties filed April 24, 1985; SPAs executed by Antonio (March 28, 1985) and Esperanza (1984) authorizing Ma. Concepcion to negotiate on their behalf.
- CFI Order dated August 29, 1985 authorized sale of three parcels adjudicated to petitioners.
- Deed of Sale and Litigation
- Deed of Sale with Assumption of Mortgage executed October 8, 1985 between petitioners (as owners) and respondents Canencia/Alforque for ₱300,000 covering the three parcels.
- Petitioners later claimed respondents had misrepresented scope of sale (only half-shares) and filed annulment, recovery of possession, and damages suit in 1995; first filing dismissed for lack of jurisdiction; refiled August 26, 2007 in RTC Branch 19.
- Lower Court Rulings
- RTC Branch 19, May 17, 2016: Declared the Deed valid; held petitioners as owners free to convey and authorized by SPA.
- CA Decision June 29, 2018 and Resolution January 16, 2019: Declared RTC judgment void for lack of jurisdiction under Rule 73, Sec. 1 (venue provision); dismissed complaint without prejudice.
Issues:
- Whether the Court of Appeals erred in declaring the RTC’s judgment void for lack of jurisdiction.
- Whether the Deed of Sale with Assumption of Mortgage is valid only as to one-half share of Federico’s estate or valid in its entirety as executed.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)