Case Digest (G.R. No. 155080) Core Legal Reasoning Model
Facts:
In the case of Soledad Calicdan, represented by her guardian Guadalupe Castillo, versus Silverio CendaAa, substituted by his legal heir Celsa CendaAa-Alaras, the controversy revolves around a parcel of unregistered land measuring 760 square meters located in Poblacion, Mangaldan, Pangasinan. The land was originally owned by Sixto Calicdan, who died intestate on November 4, 1941. He left behind a widow, Fermina, and three children, including the petitioner Soledad. On August 25, 1947, Fermina executed a deed of donation inter vivos, transferring the property to Silverio CendaAa, who subsequently moved in, constructed a residence on the land, and possessed it until his death in 1998.
On June 29, 1992, Soledad filed a complaint in the Regional Trial Court of Dagupan City for recovery of ownership, possession, and damages against Silverio. She contested the validity of the donation, alleging that the donation was void and that Silverio took advantage of her mental incompetence at t
Case Digest (G.R. No. 155080) Expanded Legal Reasoning Model
Facts:
- A 760-square-meter parcel of unregistered land in Poblacion, Mangaldan, Pangasinan was formerly owned by Sixto Calicdan, who died intestate in 1941, leaving behind his wife, Fermina, and three children.
- In 1947, Fermina executed a deed of donation inter vivos conveying the land to respondent Silverio CendaAa, who thereafter entered into possession, fenced the property, and built a two-storey residential house, residing in it until his death in 1998.
- On June 29, 1992, petitioner Soledad Calicdan (represented by her guardian Guadalupe Castillo) filed a complaint for recovery of ownership, possession, and damages, contending that the donation was void. She argued that Fermina could not validly donate the land since it was inherited by Sixto and did not form part of the conjugal property, and that the respondent had merely exercised possession that she had tolerated.
- Respondent countered that the donation was valid and that he had been in public, peaceful, continuous, and adverse possession of the land for 45 years. He further advanced that petitioner’s claim was barred by a prior judgment excluding the land from her inventory in special proceedings concerning her incompetence.
- The Regional Trial Court ruled in favor of the petitioner on November 12, 1996, ordering respondent to vacate the land and to pay damages. However, on appeal, the Court of Appeals reversed the decision, upheld the donation’s validity, and held that petitioner had lost her right by prescription.
- In reviewing the case, the Supreme Court noted conflicting factual findings between the trial court and the Court of Appeals, particularly regarding the basis of the donation, reliance on hearsay testimony, and the nature of respondent’s long and adverse possession, which raised issues of acquisitive prescription.
Issues:
- Whether the deed of donation inter vivos executed by Fermina is valid, given that she possessed only usufruct rights over the property and not full ownership.
- Whether the petitioner lost her ownership of the land by prescription, in light of respondent’s more than 45 years of adverse, continuous, and public possession.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)