Case Digest (G.R. No. 259469) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Buyayo Aliguyon v. Jeffrey a.k.a. ‘Napadawan’ Dummang, Johnny a.k.a. ‘Bidang’ Dummang, Minda Dummang, and Donato Dummang, petitioner Buyayo Aliguyon is the registered owner of a 31,850 sqm parcel in Didipio, Kasibu, Nueva Vizcaya (OCT No. P-10995). In 1968, he permitted Kiligge Dummang, father of the respondents, to occupy part of the land. After the Dummangs vacated and later returned, Buyayo’s son Robert granted them occupancy of one hectare without Buyayo’s express consent. Buyayo challenged this only after the Dummangs sued Robert for breach of contract, claiming entitlement to that hectare. In his Complaint for Recovery of Possession with Damages, Buyayo maintained he never agreed to convey land for Robert’s debt. The Dummangs counterclaimed that Robert had borrowed 72 grams of gold from Jeffrey in 1983 and never returned it; to settle the indebtedness, Buyayo allegedly agreed in April or May 1986—before tribal elders—to convey one hectare in exchange for extinguishment Case Digest (G.R. No. 259469) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background and Parties
- Buyayo Aliguyon is the registered owner of a 31,850 sq m parcel in Didipio, Kasibu, Nueva Vizcaya (OCT No. P-10995).
- In 1968, he allowed Kiligge Dummang (father of respondents Jeffrey, Donato, Johnny) to occupy a portion; they later vacated.
- Alleged Agreement and Possession
- Dummang et al. returned and obtained Robert Aliguyon’s (Buyayo’s son) permission to occupy 1 ha of the subject land to settle Robert’s indebtedness.
- No direct consent from Buyayo; he learned of the arrangement only when Dummang et al. sued Robert for breach of contract to convey the 1 ha.
- Buyayo filed a Complaint for Recovery of Possession with Damages.
- Counterclaim and Lower Court Findings
- Dummang et al. counterclaimed for reconveyance of the 1 ha, alleging a 1986 agreement: Robert received 72 g of gold from Jeffrey, failed to return it, and Buyayo offered land plus ₱8,000 to extinguish the debt.
- They took possession, made improvements, and a written agreement was reportedly lost.
- RTC and CA Decisions
- The Regional Trial Court dismissed Buyayo’s complaint, granted reconveyance, and held that Buyayo sold the 1 ha in novation of Robert’s obligation, and that Buyayo slept on his rights.
- The Court of Appeals affirmed, ruling (a) valid novation by substitution of debtor and change of object; (b) partially executed oral sale not covered by the Statute of Frauds; and (c) sale of conjugal property without wife’s consent was voidable but not annulled within 10 years.
Issues:
- Whether there was a valid novation of Robert’s loan obligation.
- Whether the oral sale is unenforceable under the Statute of Frauds.
- Whether the sale of conjugal property without the wife’s consent is void.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)