Case Digest (G.R. No. 110427) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In The Incompetent, Carmen CaAiza, represented by her legal guardian, Amparo Evangelista, petitioner vs. Court of Appeals, Pedro Estrada and Leonora Estrada, G.R. No. 110427, decided on February 24, 1997, the Supreme Court dealt with a dispute over a house and lot at No. 61 Scout Tobias Street, Quezon City. On November 20, 1989, the Regional Trial Court (RTC) of Quezon City, Branch 107, declared ninety-four-year-old Carmen CaAiza incompetent due to advanced age, cataracts, and senile dementia in SP. Proc. No. Q-89-2603, appointing her niece Amparo A. Evangelista as her legal guardian. Thereafter, on September 17, 1990, Guardian Evangelista filed in the Metropolitan Trial Court (MetroTC) of Quezon City, Branch 35, Civil Case No. 3410, an unlawful detainer suit (desahucio) against spouses Pedro and Leonora Estrada, who had occupied CaAiza’s residence rent-free since the 1960s. The amended complaint, filed within one year of the last demand dated February 27, 1990, alleged that CaA Case Digest (G.R. No. 110427) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Guardianship Proceedings
- On November 20, 1989, Carmen CaAiza, 94-year-old spinster and former U.P. professor, was declared incompetent by the R.T.C. of Quezon City, Branch 107. Her niece, Amparo A. Evangelista, was appointed legal guardian of her person and estate.
- CaAiza owned a house and lot at No. 61 Scout Tobias St., Quezon City.
- Ejectment Suit in the Metro Trial Court
- On September 17, 1990, Guardian Evangelista filed an ejectment (desahucio) suit in MetroTC, QC, Branch 35, later amended to show CaAiza as plaintiff through her guardian. The complaint alleged:
- Plaintiff’s absolute ownership under TCT No. 27147.
- Defendants Pedro and Leonora Estrada, their descendants and in-laws, had been allowed to live rent-free.
- CaAiza’s urgent need to recover the house to raise funds for her support and medical treatment.
- Two written demands (February 3 and 27, 1990) and a barangay demand to vacate were ignored.
- Filing was within one year from the first demand.
- The Estradas answered with a counterclaim, claiming they had occupied the premises since the 1960’s in consideration of their service, and relied on a purported holographic will of September 4, 1988 bequeathing the property to them.
- Trial and Appeals
- April 13, 1992 – MetroTC ruled for CaAiza: Estradas ordered to vacate and pay ₱5,000 attorney’s fees.
- October 21, 1992 – R.T.C., QC, Branch 96 reversed: held that the proper remedy was accion publiciana in the R.T.C., given the Estradas’ status as an “adopted family” and the holographic will indicating CaAiza’s intent.
- June 2, 1993 – Court of Appeals, Special First Division, affirmed the R.T.C.: agreed on accion publiciana and gave weight to the unprobated will.
- Petition to the Supreme Court and Substitution of Parties
- CaAiza (through her guardian) filed a petition for certiorari, arguing that ejectment was proper and the will irrelevant.
- Carmen CaAiza died on March 19, 1994. By resolution of June 20, 1994, her guardian Amparo Evangelista and nephew Ramon C. Nevado were substituted as petitioners under Rule 3, Section 18 of the Rules of Court.
Issues:
- Whether the proper remedy for CaAiza’s recovery of possession was an ejectment (accion interdictal) in the MetroTC or an accion publiciana in the R.T.C.
- Whether CaAiza’s legal guardian had authority to file and pursue the ejectment action.
- Whether the action survived CaAiza’s death and whether her guardian/heirs could continue representation.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)