Case Digest (G.R. No. L-5238)
Facts:
The case involves Margarita Benito and Juliana Benito as petitioners against Samuel Enero as the respondent. The action was initiated in the Court of First Instance of Nueva Vizcaya to recover a tract of land and seek damages. The respondent claimed ownership of the land based on conveyances mentioned in his answer. The trial court, presided over by Judge Jose R. de Venecia, ruled in favor of the petitioners, declaring them the absolute owners of the land and ordering the respondent to restore it to them. However, this judgment was reversed by the 5th Division of the Court of Appeals, leading to the current review.
The land in question was originally held by Estefanio Benito, the father of the petitioners, who received a homestead patent on August 8, 1930, for a three-hectare lot in barrio La Torre, Bayombong, Nueva Vizcaya. This property was conjugal, as Estefanio was married to Apolonia Corpuz. Shortly after the patent was issued, Estefanio passed away in 1934, having ver...
Case Digest (G.R. No. L-5238)
Facts:
Background of the Land Ownership
- Estefanio Benito, the father of petitioners Margarita Benito and Juliana Benito, was the holder of a homestead patent issued on August 8, 1930, covering a tract of land identified as Cadastral Lot No. 1108 in Barrio La Torre, Bayombong, Nueva Vizcaya. The land was conjugal property, as Estefanio was married to Apolonia Corpuz.
Donations by Estefanio Benito
- Shortly after the issuance of the patent, Estefanio Benito donated one-fourth of the lot to his brother Saturnino Benito and another one-fourth to his brother Eugenio Benito. These donations were made verbally or through private documents and were void because they were made within five years of the patent issuance, violating Sections 118 and 124 of Commonwealth Act No. 141.
Widow’s Confirmation of Donations
- After Estefanio Benito’s death in 1934 and the expiration of the five-year prohibition period, Apolonia Corpuz, his widow, executed notarized deeds on November 3, 1935, confirming the donations to Saturnino and Eugenio Benito. These deeds (Exhibits 3 and 5) stated that the donations were formalizations of her deceased husband’s earlier acts.
Subsequent Transfers
- On April 4, 1935, and April 13, 1936, Saturnino and Eugenio Benito sold their respective portions to Toribia Castriciones. On October 12, 1938, Toribia Castriciones donated these portions to her grandson, Samuel Enero, who took possession of the land. None of these deeds were registered.
Legal Proceedings
- Samuel Enero filed Case No. 68 in the Court of First Instance of Nueva Vizcaya to confirm his ownership and annotate the donations on the certificate of title. Apolonia Corpuz initially opposed but later withdrew her opposition, consenting to the confirmation of the donations.
- The record of Case No. 68 was lost during the war and was only recovered after the present action was filed by Apolonia Corpuz’s daughters, Margarita and Juliana Benito, against Samuel Enero to revindicate the land.
Court of Appeals’ Findings
- The Court of Appeals found that Apolonia Corpuz’s deeds (Exhibits 3 and 5) were valid and operated independently of Estefanio Benito’s void donations. The court also noted that Apolonia Corpuz’s affidavit (Exhibit 7) confirmed her consent to the donations, affecting her undivided half of the property.
Issue:
- Whether the deeds executed by Apolonia Corpuz (Exhibits 3 and 5) were valid and sufficient to transfer title to Saturnino and Eugenio Benito.
- Whether the Court of Appeals erred in interpreting the deeds and ruling in favor of Samuel Enero.
- Whether the petitioners, Margarita and Juliana Benito, had a valid cause of action to revindicate the land.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Conclusion:
The Supreme Court affirmed the decision of the Court of Appeals, dismissing the petitioners’ action and ruling that Samuel Enero was the lawful owner of the disputed portions of the land. The petitioners’ rights were limited to seeking partition of the property, which could be pursued in the pending Case No. 68.