Case Digest (G.R. No. L-16097)
Facts:
The case of Luis Almeda vs. Anastacia Manrilla, et al. (G.R. No. L-16097) was decided on May 31, 1961. The plaintiff, Luis Almeda, filed a complaint in the Court of First Instance of Laguna seeking a deed of reconveyance for a parcel of land located in Calamba, Laguna. The land in question was originally owned by his father, Catalino Almeda, who passed away on November 12, 1953. Luis claimed that he inherited the property after his father's death, asserting that his father had been in possession of the land since 1930, had declared it for taxation purposes, and had consistently paid the land taxes.
In contrast, the defendants, led by Anastacia Manrilla, contended that the land belonged to them as heirs of Marcelino Odpaga, who had purchased the property from the government. Anastacia testified that her late husband, Marcelino, had allowed Catalino to use the land on the condition that he would vacate it if Marcelino needed it back. After Catalino's death, Anastac...
Case Digest (G.R. No. L-16097)
Facts:
Background of the Parties
- Plaintiff: Luis Almeda, the only son of Catalino Almeda, who died on November 12, 1953.
- Defendants: Anastacia Manrilla (widow of Marcelino Odpaga) and her co-defendants, Reynaldo Odpaga and Nicasio Odpaga.
Subject of the Litigation
- The disputed property is a lot in Calamba, Laguna, known as Lot No. 4695 of the Calamba Friar Lands Estate, with an area of 240 square meters.
Plaintiff’s Claims
- Luis Almeda claims that the lot was among the properties left by his father, Catalino Almeda.
- He alleges that in 1930, Marcelino Odpaga delivered a document to his father, after which Catalino took possession of the lot.
- Catalino declared the property for taxation purposes in his name and paid the land taxes until his death.
- Upon Catalino’s death, Luis took possession of the property as the sole heir.
- Luis discovered an affidavit by Anastacia Manrilla in the Bureau of Lands, claiming possession of the land.
Defendants’ Claims
- Anastacia Manrilla testified that the land was bought on installment by her late husband, Marcelino Odpaga.
- Marcelino refused to sell the land to Catalino Almeda but allowed him to use it on the condition that Catalino would pay the land taxes and vacate the property if needed.
- After Catalino’s death, Anastacia demanded the return of the land, but Luis refused, claiming ownership.
- The property is covered by Transfer Certificate of Title No. T-11791, issued on July 24, 1957, in Marcelino Odpaga’s name.
- Defendants declared the property for taxation purposes and paid the taxes after the title was issued.
Trial Court’s Decision
- The trial court ruled in favor of the defendants, dismissing Luis Almeda’s complaint.
- Luis was ordered to vacate the land, turn over possession to the defendants, and pay P2.00 monthly from November 1953 until possession was delivered.
- He was also ordered to pay P300.00 as attorney’s fees and the costs of the suit.
Issue:
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Ruling:
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Ratio:
Res Judicata:
- The prior case (Civil Case No. B-142) involved the same parties, subject matter, and cause of action as the present case.
- The dismissal of the appeal in the prior case rendered the trial court’s decision final and conclusive, barring the present action under the principle of res judicata.
Ownership of the Land:
- The land was part of the Calamba Friar Lands Estate, which belonged to the government.
- Marcelino Odpaga purchased the land on installment from the government, and the title was eventually issued in his name.
- Catalino Almeda’s possession of the land was permissive and did not establish ownership.
- Tax declarations and payment of taxes by Catalino Almeda do not override the title issued in Marcelino Odpaga’s name.
Possession Based on Tolerance:
- Catalino Almeda’s possession of the land was with the understanding that he would vacate it if the owner needed it.
- Such possession does not confer ownership rights.
Conclusion:
The Supreme Court upheld the trial court’s decision, ruling that the defendants are the rightful owners of the land. The Court emphasized that the principle of res judicata barred the present action due to the prior case’s dismissal. Additionally, the Court found that Catalino Almeda’s possession of the land was permissive and did not establish ownership, especially in light of the title issued in Marcelino Odpaga’s name.