Case Digest (G.R. No. 5628)
Facts:
The case of Bernarda Aliasas et al. vs. Pedro Alcantara et al. revolves around a property dispute that originated from a sale executed without the consent of all co-owners. On June 25, 1907, the plaintiffs, Bernarda Aliasas and her children, filed an amended complaint against the defendants, Pedro Alcantara and Ambrosio Alinea, in the Court of First Instance of La Laguna. The plaintiffs claimed ownership of a lot located on Calle San Pablo in the pueblo of San Pablo, La Laguna, which was approximately half a hectare in size. This property included a house built of strong materials. The plaintiffs asserted that the lot was acquired during the marriage of Bernarda Aliasas and her deceased husband, Doroteo Alinea. Upon Doroteo's death, the property was to be divided among Bernarda and their children, including Ambrosio Alinea, who later sold the property to Pedro Alcantara without the knowledge or consent of the other heirs. The sale was made for 480 pesos, significantly les...
Case Digest (G.R. No. 5628)
Facts:
- The plaintiffs allege ownership of a lot located on Calle San Pablo in the pueblo of San Pablo, Province of La Laguna, which includes a house built of strong material.
- The lot measures approximately half a hectare and is bounded by neighboring properties—on the front by Calle San Pablo, on the right by the lot of Bernarda Aliasas, on the left by the lot of Isidro Tolentino and Agapito Aquino, and at the back by the church.
- The property was acquired during the marriage of Bernarda Aliasas and her husband, Doroteo Alinea, who is now deceased.
Background and Property Description
- At the death of Doroteo Alinea, the property was held as undivided, with one-half belonging to Bernarda Aliasas (having been acquired during the marriage) and the other half shared equally among their children—Candida, Florentino, Luis, and Ambrosio Alinea.
- It is alleged that Ambrosio Alinea, who had possession of the property, sold and transferred part of it to Pedro Alcantara without the consent or knowledge of his co-owners.
- The sale was executed at a price of 480 pesos, which is significantly lower than the true value of 1,200 pesos, thereby evidencing malice and bad faith.
Grounds of the Plaintiffs’ Claim
- The plaintiffs claim they have been unjustly deprived of control and possession of the property, resulting in damages including loss of rental income and other benefits evaluated at 1,500 pesos.
- They seek a preliminary injunction to restrain Pedro Alcantara from destroying the house (notably the windows and partitions already damaged) and request that the sale executed by Ambrosio Alinea and Alcantara be declared null and void insofar as it affects their rights.
- The relief is further compounded by a demand for judicial orders restoring their possession of the property and adjudging the defendants to pay costs.
Plaintiffs’ Relief Sought
- Pedro Alcantara, the defendant, denied the factual allegations in the complaint both generally and specifically.
- As a special defense, he argued that the plaintiffs, by their conduct, recognized the property as exclusively belonging to Ambrosio Alinea.
- He contends that he was compelled to enter into a contract of purchase with Ambrosio Alinea and asserts that such contract should not be annulled, also seeking that the plaintiffs respect the contract in force and pay the costs of the suit.
Defendant’s Position and Counterclaims
- Even before the amended complaint was filed, Ambrosio Alinea declared, in writing on November 23, 1906, that he denied selling the property to Alcantara and expressed his disinterest in the suit because of a pending Supreme Court case against Alcantara.
- The case went to trial where both parties presented testimony and documentary exhibits. Key documents included:
- Exhibit 1: A Tagalog document evidencing that Ambrosio Alinea and his wife received 300 pesos from Alcantara on February 21, 1903, secured by a lien on their house.
- Exhibit F: A Tagalog instrument executed on February 29, 1904, in which the same spouses acknowledged a loan of 480 pesos, coupled with the promise to sell the property as security should they default.
- A prior action in the court of La Laguna regarding a breach of contract (Alcantara vs. Alinea) had ruled in favor of Alcantara, affirming his claim based on the same loan instrument.
- The court in the current suit, on January 11, 1909, rendered judgment declaring the sale null and void with respect to the parts of the property belonging to the plaintiffs, while validating only a fraction in favor of Alcantara.
- Subsequently, on March 18, 1909, the judgment was modified to adjust the partition of rights—declaring null the sale as to six-eighths of the property owned by the plaintiffs and valid for one-eighth portion attributable to a deceased heir pending further litigation.
Prior Judicial Proceedings and Evidentiary Matters
- The property was originally acquired by Doroteo Alinea from Sotero Bautista in May 1895 through formal proceedings before the capitan municipal.
- Upon Doroteo Alinea’s death (June 27, 1899), his rights were transmitted by operation of law to his widow and their four children, thereby making the property common and undivided among them.
- It is contended that, as a co-heir, Ambrosio Alinea lacked the legal authority to alienate the property in its whole form, resulting in the invalidity of his sale of the property except for his potential one-eighth share.
Nature of the Property and Inheritance Issues
Issue:
- Whether the sale of the property by Ambrosio Alinea to Pedro Alcantara was legally valid given that the property was common to several heirs.
- Whether Ambrosio Alinea had the authority to sell the property without the consent of co-owners.
Validity of the Sale
- Whether the alleged unauthorized sale deprived the widow and other co-heirs (florentino, Luis, and Candida Alinea) of their rightful interest in the property.
- Whether damages resulting from loss of rentals and benefits can be attributed to this unauthorized alienation.
Infringement of Co-heirs’ Rights
- Issues arising from the initial judgment (January 11, 1909) and its subsequent modification (March 18, 1909) regarding the partition of the property rights.
- Whether the modified judgment adequately reflects the true extent of the co-heirs’ rights versus the interest acquired by Alcantara.
Effect of Prior Judgments and Subsequent Modifications
- Whether the documentary evidence (deeds, instruments in Tagalog, and prior judgments) conclusively establishes the common ownership and the invalidity of the sale covering most of the property.
- Whether the deed of transfer and its implications regarding the origin of the property provide notice to a bona fide purchaser like Alcantara.
Evidentiary Considerations
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)