Case Digest (G.R. No. L-41805)
Facts:
The case involves Joaquin Cabrera and Juana Visitacion as petitioners against the Court of Appeals and several private respondents, including Felisa Gonzaga and other members of the Gonzaga family. The dispute centers on a parcel of land measuring 4,080 square meters located in Cainta, Rizal. This land was originally owned by Diego and Patricia Gonzaga, who acquired it in 1921, presumably using conjugal funds. After their deaths, the property was inherited by their grandchildren, the private respondents. The petitioners claim ownership through an alleged sale from Eliseo Gonzaga, one of the original owners' children, while the private respondents assert their rights through succession.
The tax declaration for the property was initially in the name of Diego and Patricia Gonzaga from 1921 until 1944, when it was transferred to Eliseo Gonzaga. In 1953, the tax declaration changed again, this time to Joaquin Cabrera. In 1970, the private respondents filed a complaint in the...
Case Digest (G.R. No. L-41805)
Facts:
Ownership and Historical Background:
The subject of the controversy is a parcel of land with an area of 4,080 square meters located in Cainta, Rizal. It was originally owned by the spouses Diego and Patricia Gonzaga, who acquired it in 1921, presumably using conjugal funds. Both spouses are deceased, and the property is now claimed by their grandchildren (the private respondents) by right of succession.
Petitioners’ Claim:
The petitioners, Joaquin Cabrera and Juana Visitacion, claim ownership of the land by virtue of an alleged sale in their favor by Eliseo Gonzaga, one of Diego and Patricia Gonzaga’s children. They assert that they have been in possession of the property since 1944.
Tax Declaration History:
The tax declaration for the land was initially in the name of the spouses Gonzaga from 1921 to 1944. In 1944, it was transferred to Eliseo Gonzaga, and in 1953, it was changed to Joaquin Cabrera’s name.
Legal Proceedings:
In 1970, the private respondents filed a complaint for the recovery of the property in the Court of First Instance of Rizal, claiming that the petitioners had no right to the land. The petitioners defended their ownership by alleging a sale from Eliseo Gonzaga and referencing their pending application for registration of the land under the Torrens system.
Trial Court Decision:
The trial court ruled in favor of the private respondents, holding that the petitioners failed to prove the alleged sale to them by Eliseo Gonzaga. The court declared the private respondents as the rightful owners and enjoined the petitioners from disturbing their possession.
Appeal to the Court of Appeals:
The Court of Appeals affirmed the trial court’s decision but modified it to recognize the petitioners’ one-fifth share of the property, as conceded by the private respondents.
Issue:
- Whether the complaint was barred by laches or prescription.
- Whether the complaint was properly considered an action for reconveyance.
- Whether the respondent court erred in rejecting the petitioners’ newly-discovered evidence.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)