Case Digest (G.R. No. 148788) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Soledad CaAezo v. Concepcion Rojas (G.R. No. 148788, November 23, 2007), petitioner Soledad CaAezo filed on January 29, 1997 before the Municipal Trial Court of Naval, Biliran a complaint for recovery of a 4,169-square meter unregistered parcel in Higatangan, Naval, Biliran, and for damages against her stepmother, respondent Concepcion Rojas. CaAezo alleged she bought the land in 1939 from Crisogono Limpiado without a written contract, immediately took possession, then in 1948 left the property in the care of her father, Crispulo Rojas, when she moved to Mindanao. In 1980, she learned that respondent had entered into adverse possession and that the tax declaration was in Crispulo’s name. Respondent countered that her husband Crispulo had purchased the parcel in 1948, possessed and cultivated it until his death in 1978, and that the land was lawfully included in his estate, in which petitioner shared the proceeds. The MTC ruled for petitioner, declaring her the owner and a Case Digest (G.R. No. 148788) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Subject Matter
- Petitioners: Soledad CaAezo (substituted by William and Victoriano CaAezo), heir claiming ownership of a 4,169 sqm unregistered parcel at Higatangan, Naval, Biliran.
- Respondent: Concepcion Rojas, second wife of Crispulo Rojas, alleged possessor and heir of the same parcel.
- Underlying Transaction and Claim
- Petitioner’s Case
- Alleged oral purchase in 1939 from Crisogono Limpiado; possession taken immediately.
- Left for Mindanao in 1948 and entrusted land to her father, Crispulo Rojas; in 1980 learned respondent was in possession and discovered tax declaration in Crispulo’s name.
- Respondent’s Defense
- Crispulo Rojas bought the land in 1948, which explains the tax declaration in his name; he possessed and cultivated it until his death in 1978.
- Upon Crispulo’s death, the land was included in his estate, administered by a special administrator; petitioner received her share in the estate’s produce.
- Argued petitioner failed to implead all heirs and that long inaction constituted abandonment of her rights.
- Procedural History
- MTC Decision (July 3, 1998): Found petitioner the true owner, ordered respondent to vacate, pay ₱34,000 damages, ₱10,000 attorney’s fees, and costs.
- RTC Decision (Oct. 12, 1998): Reversed MTC on grounds of prescription and acquisitive prescription; declared property part of respondent’s legitime.
- RTC Amended Decision (Dec. 14, 1998): Set aside its prior ruling; declared petitioner owner, ordered vacatur, cancellation of tax declaration in heirs’ name, damages, and costs.
- CA Decision (Sept. 7, 2000) and Resolution (May 9, 2001): Reversed RTC Amended Decision; dismissed complaint for laches, prescription, lack of merit; upheld respondent’s ownership via adverse possession.
- Petition for Review on Certiorari filed with the Supreme Court raising procedural and substantive errors.
Issues:
- Procedural Issue
- Whether the Court of Appeals gravely abused discretion by granting respondent a second extension of time to file her petition for review.
- Substantive Issues
- Whether petitioner’s action for recovery of real property is barred by prescription and laches.
- Whether an express or implied trust existed between petitioner and her father to toll prescription.
- Whether the petitioner’s failure to implead all heirs (indispensable parties) invalidates the action.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)