Case Digest (G.R. No. 60443)
Facts:
The case involves Constantino Alvarez, Jr., Casildita Alvarez de Muertegui, and Rosalia Alvarez Vda. de Tan as petitioners against the Court of Appeals and the heirs of Segundo Garcia Fernandez as respondents. The events trace back to April 1936 when the Director of Lands filed a petition for the settlement and adjudication of titles over certain lands in the Ormoc Cadastre, including Lot No. 689, which measures approximately 338 square meters. For several years, no claims were made on Lot No. 689 despite legal notices and extensions granted by the court. Consequently, on April 1, 1942, the court issued an order of general default and dismissed the cadastral proceedings concerning the lot.
On July 22, 1940, Cecilia, Alicia, and Arturo Garcia Alvarez, claiming to be the legitimate children and heirs of the deceased spouses Segundo Garcia Fernandez and Eulogia Alvarez, filed a petition to lift the order of default. However, their petition was dismissed on technical grounds o...
Case Digest (G.R. No. 60443)
Facts:
Background of the Case
- In April 1936, the Director of Lands filed a petition with the Court of First Instance of Leyte for the settlement and adjudication of titles over certain lands in the Ormoc Cadastre, including Lot No. 689, which measures approximately 338 square meters.
- Despite notices and extensions, no one claimed Lot No. 689, leading to an order of general default and dismissal of the cadastral proceeding on April 1, 1942.
Initial Claims and Proceedings
- On July 22, 1940, Cecilia, Alicia, and Arturo Garcia Alvarez (Fernandez Children) filed a petition to lift the order of default, claiming to be the legitimate heirs of the deceased spouses Segundo Garcia Fernandez and Eulogia Alvarez. The petition was dismissed on technical grounds on September 27, 1940.
- In 1956, Constantino Alvarez, Jr., Casildita Alvarez de Muertegui, and Rosalia Alvarez Vda. de Tan (petitioners) filed a motion to reopen the proceedings, asserting they were the voluntary heirs of the deceased spouses and owners of Lot No. 689 by succession. The court granted the motion and set aside the order of default.
Trial and Initial Judgment
- The Fernandez Children failed to appear during the trial, leading to an ex parte hearing. On September 1, 1958, the court adjudicated Lot No. 689 to the petitioners.
- The Fernandez Children filed a petition for review on October 2, 1958, alleging fraud, as the petitioners' evidence contradicted their initial claim of inheritance by presenting a theory of purchase by Manuel Alvarez, who later sold the land to Constantino Alvarez, Sr. No documents of sale were presented.
Appeals and Subsequent Proceedings
- The Cadastral Court denied the petition for review on February 25, 1959. However, the Court of Appeals reversed this decision on December 4, 1969, remanding the case for a new trial.
- After the new trial, the Cadastral Court ruled in favor of the petitioners, citing laches and acquisitive prescription. The Fernandez Children appealed again, and the Court of Appeals reversed the decision on February 5, 1982, declaring the Fernandez Children as the rightful owners of Lot No. 689.
Issue:
- (Unlock)
Ruling:
- (Unlock)
Ratio:
- Amendment of Pleadings to Conform to Evidence: The petitioners' argument regarding Section 5 of Rule 10 was deemed irrelevant, as the evidence presented did not supersede or replace the allegations in their motion to reopen the proceedings.
- Finality of Judgments: The 1940 decision was not on the merits and could not be invoked as res adjudicata. The doctrine of res adjudicata requires a prior judgment on the merits, which was absent in this case.
- Laches and Prescription: The petitioners' possession of Lot No. 689 was not adverse to the Fernandez Children, as they were merely administrators. Adverse possession requires clear repudiation of the owner's title, which only occurred in 1956 when the petitioners filed their motion to reopen the proceedings. Thus, the claim of acquisitive prescription failed.
- Ownership and Succession: The Court of Appeals correctly found that the Fernandez Children were the rightful heirs of Segundo Garcia Fernandez and Eulogia Alvarez, as the petitioners' claims were inconsistent and unsupported by evidence.