Title
Angeles vs. Razon
Case
G.R. No. L-13679
Decision Date
Oct 26, 1959
Domitila Angeles sought title transfer for Lot 848, claiming sole ownership as heir, but heirs of Eulalio Razon contested, citing shared ownership. SC ruled cadastral court lacked jurisdiction; dispute required ordinary action.
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Case Digest (G.R. No. L-13679)

Facts:

  1. Petition Filed by Domitila Angeles:

    • On August 31, 1955, Domitila Angeles filed a petition in Cadastral Case No. 11, Record No. 18, Court of First Instance of Pampanga, under Section 112 of the Land Registration Act.
    • She claimed to be the sole heir of spouses Santiago Angeles and Anastacia Guevarra.
    • She alleged that the spouses purchased Lot 848 of the Bacolor Cadastral Survey from Paulina Angeles, wife of Eulalio Razon, on June 20, 1929.
    • The lot was registered under Original Certificate of Title No. 8168 in the name of Eulalio Razon.
    • Domitila asserted that the heirs of Eulalio Razon sold their rights to Ignacio Angeles, who verbally ceded his rights to Santiago Angeles (Domitila’s father).
    • She claimed possession of the lot and the house thereon for 30 years.
    • She sought the cancellation of OCT No. 8168 and the issuance of a new transfer certificate of title in her name.
  2. Opposition by the Heirs of Eulalio Razon:

    • On September 23, 1955, Pedro Razon and other heirs of Eulalio Razon filed an opposition.
    • They claimed to be the only children and direct descendants of Eulalio Razon, who was the original and exclusive owner of Lot 848.
    • They asserted ownership of 5/6 of the lot, with Domitila Angeles owning only 1/6.
    • They argued that the deed of donation relied upon by Domitila was void for lack of a public instrument, signatures of donors, and acceptance by the donee.
  3. Motion to Dismiss:

    • On October 21, 1955, the oppositors filed a motion to dismiss, arguing that the court lacked jurisdiction because the ownership of the lot was seriously disputed.
    • They contended that the issue should be resolved in an ordinary action, not in a cadastral proceeding.
    • The trial court granted the motion and dismissed the petition.
  4. Appeal to the Supreme Court:

    • Domitila Angeles appealed to the Court of Appeals, which certified the case to the Supreme Court, as only questions of law were involved.

Issue:

  1. Whether the trial court, acting as a cadastral court, had jurisdiction to entertain the petition under Section 112 of the Land Registration Act, given the disputed ownership of the property.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)


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