Title
Arbolario vs. Court of Appeals
Case
G.R. No. 129163
Decision Date
Apr 22, 2003
A dispute over inheritance and land ownership arises when petitioners claim to be the legitimate children of the deceased, but fail to provide sufficient evidence, leading the Court of Appeals to rule in favor of the respondents and deny the petition for review.
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Case Digest (G.R. No. 129163)

Facts:

  • Dispute Context: The case "Arbolario v. Court of Appeals" revolves around issues of inheritance and land ownership.
  • Petitioners: Voltaire Arbolario, Lucena Arbolario Ta-ala, Fe Arbolario, Exaltacion Arbolario, Carlos Arbolario, and Spouses Rosalita Rodriguez and Carlito Salhay.
  • Claim: Petitioners assert they are legitimate children of Juan Arbolario and seek a share in the inheritance of their alleged half-sister, Purificacion Arbolario.
  • Respondents: Irene Colinco, Ruth Colinco, Orpha Colinco, and Goldelina Colinco, descendants of Agueda Colinco, one of the original owners of the disputed lot.
  • Initial Ruling: The RTC of Kabankalan, Negros Occidental, ruled in favor of the Arbolarios, invalidating the Declaration of Heirship and Partition Agreement by the Colincos.
  • Appeals Court Decision: The CA reversed the RTC decision, prompting the petitioners to seek a review by the Supreme Court.
  • Central Issues: Legitimacy of the petitioners, validity of the Salhays' land purchase, and the RTC's jurisdiction to partition the disputed lot.

Issue:

  • (Unlock)

Ruling:

  1. The petitioners did not provide sufficient evidence to prove their legitimacy and thus are not entitled to inherit from Purificacion Arbolario.
  2. There was no sufficient evidence to prove that the Salhays had validly purchased the portion of the land in question.
  3. The RTC did n...(Unlock)

Ratio:

  1. Legitimacy of Petitioners:

    • The legitimacy of the petitioners must be judicially established.
    • Petitioners failed to provide clear and substantial evidence of the marriage between Juan Arbolario and Francisca Malvas.
    • Presumption of legitimacy cannot be invoked without proof of a valid marriage.
    • CA's factual findings indicated that the petitioners were illegitimate children, barring them from inheriting from Purificacion under Article 992 of the Civil Code.
  2. Evidence of Purchase:

    • No clear and reliable evidence supported the claim that the Salhays had purchased the disputed lot portion.
    • CA found that the Salhays failed to present any written contract or substantial proof of purchase.
    • Petitioners did not provide supporting evidence to overturn the CA's findings.
  3. Jurisdiction to Partition:

    • RTC did not have jurisdiction to partition the disputed lot.
    • Partition aims to end co-owne...continue reading

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