Case Digest (G.R. No. 257454)
Case Digest (G.R. No. 257454)
Facts:
Cali Realty Corporation, represented by Dr. Camilo M. Enriquez, Jr. v. Paz M. Enriquez, G.R. No. 257454, July 26, 2023, Supreme Court Second Division, Lazaro-Javier, J., writing for the Court.The dispute arose from land titles and corporate shares traced to properties registered in the name of Camilo M. Enriquez, Sr. during his marriage to Librada Machica Enriquez (married May 20, 1939; Librada died June 23, 1995). The couple had five children including Paz M. Enriquez and Camilo M. Enriquez, Jr. On October 5, 1995, Camilo, Sr. executed a Deed of Assignment conveying numerous parcels (totaling 530,491 sq. m.) to Cali Realty Corporation (CRC), a corporation organized August 14, 1995 whose incorporators included Camilo, Sr. and all his children except Paz.
In 2001 Paz annotated an adverse claim on twelve Transfer Certificates of Title (TCTs) in CRC’s name asserting her one‑sixth share of her mother’s one‑half conjugal share. CRC filed a Petition for Cancellation of Adverse Claim; the trial court initially granted cancellation. The Court of Appeals, however, in a Decision dated June 17, 2013 (CA-G.R. CV No. 03725) reversed, finding genuine issues and that Paz’s counterclaim was compulsory; that decision attained finality on August 1, 2013 and the case was remanded for trial.
After trial (each party presented one witness and TCTs), the Regional Trial Court, Branch 9, Tacloban City, by Decision dated August 22, 2018 denied CRC’s petition, maintained Paz’s adverse claims, and ordered CRC to convey to Paz one‑sixth of one‑half of the properties, to transfer 242,000 shares (19.36%) of CRC to Paz, to account for proceeds and to pay litigation expenses and attorneys’ fees. The Court of Appeals affirmed that Decision on September 29, 2020 and denied reconsideration on June 9, 2021. CRC filed this Petition for Review on Certiorari under Rule 45.
Issues:
- Under Rule 45, may the Court review the factual findings of the trial court and the Court of Appeals in this case?
- Were the subject properties conjugal (thus giving Paz a one‑sixth share of her mother’s half) or paraphernal, and did the lower courts correctly apply the presumption of conjugal ownership?
- Was Paz’s counterclaim properly characterized as compulsory and, on the merits, can the Court uphold the trial court’s transfer of CRC shares and related relief without further factual determination (including computation of Paz’s legitime)?
- Was piercing of the corporate veil appropriate given the record and, if so, could the Court effect the remedies ordered by the courts below?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)