Case Digest (G.R. No. 28067)
Facts:
The case involves Basilia Arayata as the plaintiff and appellant against Florentino Joya and others as defendants and appellants. The events leading to this case began with Cecilio Joya, who inherited the right to lease six lots of friar lands in Santa Cruz de Malabon, Tanza, Cavite, from his deceased parents. On June 4, 1906, he married Basilia Arayata. Following the acquisition of the land by the Insular Government, Cecilio continued leasing the land and later purchased it in installments under Act No. 1120. The lots in question include Nos. 1031, 1058, 1086, 1153, 2352, and 547. To secure lots 1153 and 2352, Cecilio had Pedro Tiongco purchase them on his behalf, later transferring the rights back to Cecilio through a donation.
Cecilio Joya executed a will on April 27, 1919, bequeathing various lots to different individuals, including Florentino Joya. He died on May 26, 1919, and his will was probated shortly thereafter. Disputes arose during the testamentary proceedings...
Case Digest (G.R. No. 28067)
Facts:
Background of the Parties and Property
- Cecilio Joya inherited the right to lease six lots of friar lands in Santa Cruz de Malabon, Tanza, Cavite, from his deceased parents.
- On June 4, 1906, Cecilio Joya married Basilia Arayata, the plaintiff-appellant.
- After the Insular Government acquired the land, Cecilio Joya continued leasing the lots under the provisions of Act No. 1120.
Purchase of the Lots
- During his marriage to Basilia Arayata, Cecilio Joya purchased the leased lots on installment from the Government under Act No. 1120. The lots were designated as Nos. 1031, 1058, 1086, 1153, 2352, and 547.
- Due to legal limitations on the number of lots a purchaser could acquire, lots Nos. 1153 and 2352 were excluded from the purchase. To retain them, Cecilio Joya had Pedro Tiongco purchase these lots using funds provided by Cecilio. Pedro Tiongco later transferred his rights to Cecilio Joya by donation, which was approved by the Director of Lands.
Conveyances and Will
- On April 24, 1919, Cecilio Joya conveyed his right to lot No. 1058 to Florentino Joya for P2,000, which was approved and registered.
- On May 11, 1919, Cecilio Joya conveyed his right to lot No. 547 to Marcelina Joya and Francisco Joya for P450, which was also approved and registered.
- On April 27, 1919, Cecilio Joya executed a will devising the lots to various defendants:
- Lot No. 1058 to Florentino Joya,
- Lot No. 1086 to Pablo Joya,
- Lot No. 1031 to Delfin and Felicisima Blancaflor,
- Lot No. 1153 to Agustin and Pedro Joya,
- Lot No. 2352 to Feliciano and Asuncion Bobadilla,
- Lot No. 547 to Marcelina and Francisca Joya.
Death of Cecilio Joya and Testamentary Proceedings
- Cecilio Joya died on May 26, 1919. His will was probated, and Florentino Joya was appointed executor.
- In March 1920, Florentino Joya presented an agreement of partition, which was opposed by Basilia Arayata, who claimed her signature was obtained by fraud.
Possession of the Lots
- At the time of Cecilio Joya’s death, he had not fully paid for the lots. The defendants were in possession of the lots and enjoyed their products.
Issue:
- Were Cecilio Joya’s conveyances of his interest in lot No. 1058 to Florentino Joya and in lot No. 547 to Marcelina and Francisca Joya fraudulent?
- Were Cecilio Joya’s legacies of lots Nos. 1031, 1086, 1153, and 2352 to the other defendants null and void?
- Does Basilia Arayata, as the surviving spouse, have an exclusive right to all the lots in question?
- Is Basilia Arayata entitled to the possession and products of the lots?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Conclusion:
The Supreme Court modified the trial court’s judgment, ruling that:
- The conveyances of lots No. 1058 and 547 were valid.
- The legacies of lots Nos. 1031, 1086, 1153, and 2352 were null and void.
- Basilia Arayata is entitled to the exclusive ownership and possession of the lots, as well as their products, after deducting necessary expenses.
The defendants were ordered to return the lots and their products to Basilia Arayata.