Case Digest (G.R. No. L-22487) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In 1916, Eulogio Atilano I acquired by purchase from Gerardo Villanueva the entire Lot No. 535 in the Municipality of Zamboanga, with Transfer Certificate of Title No. 1134 issued in his name. Four years later, he subdivided the property into Lots 535-A, 535-B, 535-C, 535-D, and 535-E. On May 18, 1920, he executed a deed of sale purporting to convey Lot No. 535-E to his brother Eulogio Atilano II for ₱150.00; Eulogio II secured TCT No. 3129 over Lot 535-E. The remaining portions were sold to third persons, and Lot 535-A remained with Eulogio I, passing upon his death to Ladislao Atilano, who obtained TCT No. T-5056. In 1952, Eulogio II and his children, now co-owners, had TCT No. 4889 issued in their names. In 1959, a resurvey revealed that the lot actually conveyed in 1920 was 535-A, not 535-E, and that Lot 535-E had remained in the possession of Eulogio I and thereafter of Ladislao. On January 25, 1960, Eulogio II’s heirs (plaintiffs-appellees: Asuncion, Cristina, Rosario Atil Case Digest (G.R. No. L-22487) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Acquisition of the original parcel
- In 1916, Eulogio Atilano I purchased Lot No. 535 from Gerardo Villanueva and secured Transfer Certificate of Title (TCT) No. 1134 in his name.
- Subdivision and initial sales (1920)
- The entire Lot No. 535 was subdivided into Lots Nos. 535-A, 535-B, 535-C, 535-D and 535-E.
- On May 18, 1920, Eulogio I sold “Lot No. 535-E” to his brother, Eulogio II, for ₱150.00; Eulogio II obtained TCT No. 3129.
- Lots 535-B, 535-C and 535-D were sold to third parties; Eulogio I retained the portion known as Lot 535-A, which upon his death passed to Ladislao Atilano, issued TCT No. T-5056.
- Subsequent registrations and possession
- On December 6, 1952, Eulogio II (now a widower) and his children registered co-ownership of “Lot No. 535-E” under TCT No. 4889.
- In July 1959, a resurvey revealed that the vendee actually occupied Lot 535-A and the vendor Lot 535-E, contrary to the deed’s lot numbers.
- Litigious proceedings (1960)
- On January 25, 1960, the heirs of Eulogio II filed suit to exchange possession—offering Lot 535-A for Lot 535-E—which the defendants refused.
- The defendants counterclaimed, alleging an involuntary drafting error in the 1920 deed: the sale intended Lot 535-A, not 535-E; they also asserted adverse possession and sought issuance of a proper deed for Lot 535-E.
- Trial court decision
- The Court of First Instance ruled for the plaintiffs solely on the ground that, under the Torrens system, registered titles cannot be acquired by prescription.
- The trial court did not address the defendants’ mistake claim.
Issues:
- Was there an involuntary error in the lot designation of the May 18, 1920 deed of sale?
- What was the true intention of the parties in that deed—conveyance of Lot 535-A or Lot 535-E?
- Is the remedy of reformation under Articles 1359 et seq. of the New Civil Code applicable?
- Can the defendants acquire registered land by adverse possession under the Land Registration Act?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)