Title
Anonuevo vs. Anonuevo
Case
G.R. No. L-22269
Decision Date
Dec 20, 1967
Siblings dispute inheritance over six parcels of land; reconstituted titles deemed fraudulent, partition ordered for rightful heirs.
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Case Digest (G.R. No. L-22269)

Facts:

    Parties and Background

    • Plaintiffs
    • Amando, Francisco I, Teofila, and Benita Anonuevo, the children of the deceased Tomas Anonuevo by his first marriage to Pascuala Baldivina.
    • Defendants
    • Alberto, Francisco II, Florencio, David, and Mercedes Anonuevo, the half-siblings of the plaintiffs and children of Tomas Anonuevo by his second marriage to Ciriaca Apon.
    • Eduvijis and Brigido Anonuevo, children of the deceased Sixto Anonuevo (a son of Tomas Anonuevo by his first marriage).
    • Oscar and Fe Enciso, children of Rafaela Anonuevo, who is a daughter of Tomas Anonuevo by his second marriage.

    Subject Matter of the Case

    • Plaintiffs initiated an action for the partition of six (6) parcels of land allegedly acquired by their father during his first marriage, using funds originating from the paraphernal property of Pascuala Baldivina.
    • The disputed properties include one parcel in Legaspi, Albay and several parcels in Libog, Albay, with detailed descriptions given in the complaint.
    • A counterclaim (or cross-complaint) was also filed by the defendants for the partition of nine (9) other lots, of which the three (lots Nos. 5705, 5765, and 5805) are particularly contested in this appeal.

    Procedural History and Property Possession

    • After the death of Tomas Anonuevo in 1950, following the death of his second wife, the plaintiffs, then minors, sought a partition of the lands.
    • Defendants proposed that the lands be held by one of their siblings, Alberto Anonuevo, for the benefit of all heirs.
    • In 1955, defendants (except for Eduvijis, Brigido, Oscar, and Fe) assumed exclusive possession of the lands and excluded the plaintiffs and the other named defendants from any benefit of the produce from these lands.

    Title Issues and Reconstitution Proceedings

    • Original Certificates of Title for the lots were issued in the name of Tomas Anonuevo before his death (December 17, 1950).
    • Teofila Anonuevo later filed a petition for the reconstitution of said original certificates in Cadastral Case No. RT-457 on May 31, 1957, asserting that the certificates should be in her name and that of her husband, Juan C. Arandia, because they had been lost or destroyed.
    • Branch I of the Court of First Instance of Albay initially granted the petition on August 20, 1957, but after a motion for reconsideration by defendant Alberto Anonuevo was filed, the petition was denied on February 28, 1958.
    • Subsequently, on April 8, 1958, Teofila Anonuevo filed another petition for the reconstitution—this time in Branch II (Cadastral Case No. 506)—for the reconstitution of transfer certificates of title covering lots Nos. 5705, 5765, and 5805.
    • Branch II granted the motion on August 1, 1958, leading to the issuance of Transfer Certificates of Title Nos. RT-952(NA), 951(NA), and 950(NA) on September 2, 1958, in the name of Teofila Anonuevo and Juan C. Arandia.

    Allegations of Fraud and Misrepresentation

    • Defendants alleged that the reconstitution of the transfer certificates of title was achieved through fraud, misrepresentation, and deceit.
    • They contended that Teofila Anonuevo and her husband never legitimately acquired the lots through valid purchase transactions, given that no such transfer certificates had existed prior to the reconstitution proceedings.
    • The evidence suggested inconsistencies in the timeline of alleged purchases (purportedly occurring between 1933 and 1938) and the actual issuance of registration decrees dating from 1927.
    • The absence of original valid transfer certificates until the reconstitution applications further cast doubt on the genuineness of the alleged transactions.

Issue:

  • Whether the reconstitution of the transfer certificates of title for the contested lots (Nos. 5705, 5765, and 5805), allegedly obtained through fraud, misrepresentation, and deceit, compromises the principle of indefeasibility inherent in the Torrens system.
  • Whether Teofila Anonuevo, having obtained reconstituted transfer certificates of title through questionable proceedings, holds full title or merely acts as a trustee for the benefit of all the heirs of Tomas Anonuevo.
  • Whether the lower court erred in ordering the partition of the lots among the heirs rather than upholding the reconstituted transfer certificates as valid, unassailable titles under the principle of indefeasibility.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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