Case Digest (G.R. No. 202889)
Case Digest (G.R. No. 202889)
Facts:
Caranto v. Caranto, G.R. No. 202889, March 02, 2020, Supreme Court Second Division, Hernando, J., writing for the Court. Petitioner Rodolfo Caranto sued respondent Anita Agra Caranto in Civil Case No. MC01-1454 (RTC, Branch 212, Mandaluyong City) seeking cancellation of title and reconveyance of a 347‑sq.m. parcel (TCT No. 7884), one‑half ownership, and attorney’s fees; Anita answered and filed a compulsory counterclaim for damages. Rodolfo alleged he was a son of Guillerma Lopez‑Caranto and therefore entitled to inherit from Juan L. Caranto (Anita’s deceased husband); he relied on a 1972 Extrajudicial Settlement of Guillerma’s estate, a 1972 Special Power of Attorney, and a purported 1990 Deed of Waiver by Rizalina relinquishing rights to Rodolfo.At trial the RTC found Rodolfo failed to prove filiation with Juan: several key documents were only photocopies, his proofs did not establish that Juan’s mother was Guillerma, and Rodolfo failed to produce a birth certificate for Juan to rebut testimony and the marriage contract suggesting Juan’s mother was Dolores Lopez. The RTC dismissed the complaint, ruled for Anita on her compulsory claim, and awarded exemplary damages (Php20,000), attorney’s fees (Php20,000) and litigation expenses (Php10,000) in an October 22, 2007 Decision.
Rodolfo appealed to the Court of Appeals (CA). In an April 18, 2012 Decision in CA‑G.R. CV No. 90285 (later referenced by the CA as CA‑G.R. CV No. 92085), the CA affirmed the RTC’s factual finding that Rodolfo failed to prove his relationship to Juan and thus could not sustain reconveyance or cancellation; however, the CA deleted the exemplary damages award but affirmed attorney’s fees and litigation expenses. Rodolfo’s Motion for Reconsideration was denied by CA Resolution dated July 31, 2012. Rodolfo then filed a Petition for Review on Certiorari under Rule 45 before the Supreme Court.
Issues:
- Whether this Court may review the CA’s factual findings under a Petition for Review on Certiorari under Rule 45 (i.e., whether the petition raises questions of law or of fact).
- Whether Anita is estopped from impugning the relationship between her late husband Juan and Rodolfo.
- Whether the Extrajudicial Settlement and the Deed of Waiver sufficed to prove that Rodolfo is entitled to one‑half of the subject property by inheritance and waiver.
- Assuming Juan’s mother was Dolores Lopez, whether Rodolfo is entitled to the entire subject property as heir of Guillerma Lopez‑Caranto.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)