Case Digest (G.R. No. 218731) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Nicomedes Augusto, et al. v. Antonio Carlota Dy and Mario Dy, G.R. No. 218731, decided on February 13, 2019 under the 1987 Constitution, the petitioners—Nicomedes Augusto, Gomercindo Jimenez, Marcelino Paquibot, and Roberta Silawan—claimed valid titles over portions of Lot No. 4277 in Lapu-Lapu City originally registered under OCT No. RO-3456 in the names of spouses Sixto Silawan and Marcosa Igoy. Respondent Antonio Dy asserted that he acquired 2,363.5 sq m of the same parcel by an uncontested chain of sales dating back to 1965, while respondent Mario Dy claimed title to 1,332.5 sq m through a separate lineage of conveyances. In 2001, Roberta, as sole heir, executed an extrajudicial settlement confirming her father’s 1960s sales and partitioning the property among the petitioners, leading to the issuance of Transfer Certificates of Title in their names. Antonio sued in 2002 for nullity of those deeds, titles, tax declarations and for repartition, and Mario intervened. At pre- Case Digest (G.R. No. 218731) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Property and Original Registration
- Lot No. 4277 (5,327 sq m) in Lapu-Lapu City registered under OCT No. RO-3456 in the names of spouses Sixto Silawan and Marcosa Igoy.
- The spouses had one child, Roberta Silawan, sole heir.
- Chain of Conveyances
- March 31, 1965: Sixto sold entire 5,327 sq m to Severino Silawan; May 7, 1965: Severino sold 2,663.5 sq m to Isnani Maut and Lily Silawan; September 16, 1966: Isnani and Lily sold the same 2,663.5 sq m to Filomeno Augusto and Lourdes Igot.
- November 25, 1989: Filomeno and Lourdes sold 2,363.5 sq m to Antonio Dy; remaining 300 sq m to Nicomedes and Gaudencia Augusto.
- Extrajudicial Settlement and New Titles
- June 27, 2001: Roberta, as sole heir, executed an Extrajudicial Settlement confirming all prior sales and adjudicating the entire lot to herself.
- December 14, 2001: Register of Deeds annotated OCT No. RO-3456, cancelled it, and issued TCTs in favor of petitioners:
- TCT No. 48562 – Nicomedes & Gaudencia (300 sq m)
- TCT No. 48563 – Gomercindo Jimenez (1,331 sq m)
- TCT No. 48564 – Marcelino Paquibot (1,332.5 sq m)
- TCT No. 48565 – Roberta (2,363.5 sq m)
- Court Proceedings
- July 16, 2002: Antonio filed for nullity of deeds and partition; Mario Dy intervened with separate claim.
- RTC: Petitioners defaulted at pre-trial; respondents presented evidence ex parte; November 9, 2012 decision nullified extrajudicial settlement, related deeds and TCTs; ordered a new partition among Antonio, Mario, Gomercindo, Nicomedes.
- CA: November 20, 2014 affirmed the RTC in toto; June 2, 2015 denied motion for reconsideration. Petitioners elevated case to SC.
Issues:
- Whether the RTC properly declared petitioners in default and allowed ex parte presentation of evidence.
- Whether the cancellation of petitioners’ TCTs and the new partition ordered by the lower courts was proper.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)