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...

Facts:

Background and Land Description

• Estefanio Benito was issued a homestead patent on August 8, 1930 covering a tract of land of more than three hectares in barrio La Torre, municipality of Bayombong, Province of Nueva Vizcaya; the property was identified as Cadastral Lot No. 1108 and constituted conjugal property with his wife, Apolonia Corpuz.
• The land later became the subject of multiple acts of donation and subsequent conveyances.

Donations and Subsequent Formalizations

• Shortly after the issuance of the patent, Estefanio Benito, during his lifetime, orally donated one-fourth of the land to his brother Saturnino Benito and one-fourth to his other brother, Eugenio Benito. These donations were considered legally void due to their informal execution (verbal or by private documents) and the fact they were made within the five-year prohibition period.
• After Estefanio Benito’s death in 1934 and the expiration of the statutory period, on November 3, 1935, his widow, Apolonia Corpuz, executed two notarized deeds (Exhibits 3 and 5) to formalize the donations previously made to Saturnino and Eugenio Benito, thereby attempting to confirm and legitimize the transfers.

Subsequent Transactions and Possession

• Saturnino Benito and Eugenio Benito subsequently sold their respective interests to Toribia Castriciones on April 4, 1935, and April 13, 1936, and delivered possession of the properties in exchange for payments of P320 and P180 respectively.
• On October 12, 1938, Toribia Castriciones donated both portions to her grandson, Samuel Enero, who accepted the donation and took immediate possession.
• Notably, none of the deeds (including the donations and subsequent transfers) were registered, and cognizant of the defects in his title, Samuel Enero later instituted a case (Case No. 68) in the Court of First Instance to vindicate his title and possession of the land.

Initiation of the Present Action and Litigation History

• The present action was filed by the daughters of Apolonia Corpuz (Margarita and Juliana Benito) seeking to be adjudged the absolute owners of the land, to have the donations confirmed, and to have the donation by Toribia Castriciones annotated on the certificate of title.
• At trial, the court (Judge Jose R. de Venecia) ruled in favor of the plaintiffs by declaring them the absolute owners and ordering the defendant, Samuel Enero, to restore possession of the land.
• On appeal, the 5th Division of the Court of Appeals reversed the trial court’s judgment, leading to the present review by the Supreme Court.

Evidentiary Issues and Affidavits

• Apolonia Corpuz, though not a direct party to the petition at bar, filed an affidavit (Exhibit 7) in which she indicated that she had withdrawn her verbal opposition and consented to the relief favored by the petitioner.
• At trial, she admitted to signing Exhibits 3 and 5 but later testified that her signature was based on an understanding that the documents would effect the transfer of title in the name of her daughters, testimony that the Court of Appeals did not give substantial weight.

Deed Interpretation and Extent of Conveyance

• A primary dispute arose as to whether the deeds (Exhibits 3 and 5) merely served as the formalization of Estefanio Benito’s premature and void donations or whether they functioned as independent instruments that effectively conveyed title.
• A related issue concerned the extent of the estate conveyed by these deeds—whether they transferred the entire undivided interest of Apolonia Corpuz in Lot No. 1108 or only a specified portion (the northern half) of the property.

Plaintiff’s Claim and Underlying Defect in the Action

• The petitioners (Apolonia Corpuz’ daughters) sought to recover the specific portions donated as though they held exclusive fee simple title over the entire lot, despite only inheriting one-half interest and sharing the property as co-owners in undivided form.
• The Court of Appeals, and later the Supreme Court, pinpointed that the correct remedy for such disputes among co-owners would be partition and not a declaration of exclusive ownership over a specifically identified portion.

Issue:

Validity and Interpretation of the Deeds

• Whether the notarized deeds (Exhibits 3 and 5), executed by Apolonia Corpuz after the expiry of the five-year prohibition period, are valid instruments that autonomously conveyed title or if they were merely intended to formalize Estefanio Benito’s earlier void donations.
• Whether the deeds are to be interpreted as transferring the entire undivided half of the property owned by Apolonia Corpuz or only a specific portion (the northern half) of the land.

Appropriate Relief and Cause of Action

• Whether the petitioners have a valid cause of action in seeking absolute ownership of the land when their entitlement is limited to a partition of the property.
• Whether the trial court’s remediation (awarding full possession and absolute ownership) exceeded the scope of the proper remedy given the co-ownership interests involved.

Impact of Subsequent Transactions and Possession on Title

• Whether Samuel Enero’s long continuous possession, based on the donation and subsequent transactions, secures his title despite the defects in the earlier deeds and the unsettled nature of the original donations.
• Whether the pending case (Case No. 68) should resolve outstanding issues regarding the partition and extent of Apolonia Corpuz’ share in the homestead.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)