Facts:

The case involves a petition for review on certiorari filed by Nora B. Calalang-Parulan and Elvira B. Calalang (petitioners) against Rosario Calalang-Garcia, Leonora Calalang-Sabile, and Carlito S. Calalang (respondents). The dispute centers around a parcel of land identified as Lot 1132, Cad. 333, with an area of 1,266 square meters, located in Brgy. Burol 2nd, Municipality of Balagtas, Province of Bulacan. The respondents filed a Complaint for Annulment of Sale and Reconveyance of Property on June 10, 1991, asserting their ownership over the land, which they claimed was acquired from their mother, Encarnacion Silverio, through succession. The respondents argued that their father, Pedro Calalang, had two marriages; the first with Encarnacion Silverio, who died on June 7, 1942, and the second with Elvira B. Calalang, whom he married on November 6, 1967. They contended that the land was acquired during the first marriage and that Pedro Calalang fraudulently claimed sole owners...

Facts:

Background of the Case

The case involves a dispute over a parcel of land identified as Lot 1132, Cad. 333, Bigaa Cadastre, located in Brgy. Burol 2nd, Balagtas, Bulacan. The respondents, Rosario Calalang-Garcia, Leonora Calalang-Sabile, and Carlito S. Calalang, filed a Complaint for Annulment of Sale and Reconveyance of Property against the petitioners, Nora B. Calalang-Parulan and Elvira B. Calalang, asserting their ownership over the land.

Ownership Claims

The respondents claimed that the land was acquired by their parents, Pedro Calalang and Encarnacion Silverio, during their marriage. Upon Encarnacion's death in 1942, the respondents, as compulsory heirs, inherited the property. However, Pedro Calalang, after marrying Elvira B. Calalang, fraudulently obtained a free patent for the land in 1974, registering it solely in his name. He later sold the land to Nora B. Calalang-Parulan in 1984, which the respondents contested, arguing that the sale was void due to lack of consent from the co-owners and that it was a simulated sale.

Petitioners' Defense

The petitioners countered that the land was acquired during Pedro Calalang's second marriage to Elvira B. Calalang, making it conjugal property of the second marriage. They also denied the allegation of a simulated sale, asserting that Nora B. Calalang-Parulan had the capacity to pay for the land. They further argued that the respondents' cause of action was barred by laches, estoppel, and prescription.

Trial Court Ruling

The Regional Trial Court (RTC) ruled in favor of the respondents, declaring the land as part of the conjugal property of Pedro Calalang's first marriage. The court ordered the reconveyance of the respondents' shares and awarded damages.

Court of Appeals Decision

The Court of Appeals (CA) modified the RTC's decision, holding that Pedro Calalang was the sole and exclusive owner of the land. The CA ruled that the respondents did not acquire successional rights to the land upon Encarnacion's death but were entitled to shares as heirs of Pedro Calalang upon his death. The CA also found the sale to Nora B. Calalang-Parulan to be fraudulent and ordered the reconveyance of the respondents' shares.

Issue:

The primary issue in this case is whether Pedro Calalang was the exclusive owner of the disputed property prior to its transfer to Nora B. Calalang-Parulan. The resolution of this issue determines the validity of the sale and the respondents' claim to the property.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Conclusion:

The Supreme Court ruled in favor of the petitioners, holding that Pedro Calalang was the sole owner of the disputed property and that the sale to Nora B. Calalang-Parulan was valid. The respondents' claims were dismissed for lack of evidence.