G.R. No. L-20122 - Castro vs. Court of Appeals

The original application for the registration and confirmation of title was filed by Alejandra Austria on June 5, 1948, covering ten parcels of land in Mangatarem, Pangasinan (located in the barrios of Punglo Grande, Caviernesan, and in the poblacion).
Socorro A. Castro filed an opposition, alleging that the lands had been donated to her by Alejandra Austria in 1939.
On March 2, 1950, the Court of First Instance rendered judgment finding that Alejandra Austria had been in possession of the lands “in concept of owner” since 1894, and ruled that by her donation the title should be registered in the name of the donee, Socorro A. Castro—subject to the reserved usufruct for the donor for her lifetime.

Alejandra Austria was the widow of the deceased Antonio Ventenilla. On March 31, 1950, cousins (nieces and nephews) of Antonio Ventenilla, claiming heirship, filed a petition to set aside the previous judgment and the order of default, seeking to have their opposition admitted.
Their petition was granted and the case was subsequently set for a new trial.
During the pendency of the case, Alejandra Austria died and Socorro A. Castro was substituted as the applicant.

Group One (Parcels Nos. 1, 2, 3, and 10): These passed into the possession of Alejandra Austria by virtue of the will of Antonio Ventenilla and an agreement reached at trial.
Group Two (Parcels Nos. 4, 5, 6, 7, 8, and 9): There was no agreement regarding these; the oppositors contended that these belonged to the deceased, while the petitioner maintained that they were acquired by purchase.

Documentary evidence showed that the parcels in the second group were bought by Alejandra Austria (with relevant deeds of sale and tax receipts), while testimonial evidence confirmed long possession as owner.

One pivotal issue was whether the possession of parcels Nos. 1, 2, 3, and 10 indicated that Alejandra Austria was merely a life usufructuary (with the naked ownership resting with the oppositors as collateral heirs) or the owner in fee simple (as residuary legatee under Antonio Ventenilla’s will).
The Court of Appeals remarked ambiguously on this issue, noting that mere possession did not necessarily imply inclusion in the residuary legacy; however, precedent evidenced that she had long been in the position of owner.
Additionally, the donation of all ten parcels executed by Alejandra Austria in favor of Socorro A. Castro was scrutinized:

The donation, executed on September 22, 1939, was termed “donacion onerosa” with conditions which restrained Socorro from enjoying the fruits of the lands during Alejandra’s lifetime.
The instrument indicated that after the donor’s death, the naked ownership and usufruct would consolidate in favor of Socorro A. Castro.
Oppositors argued that the donation was mortis causa and void due to noncompliance with formalities required for a testamentary disposition; however, evidence and judicial precedent (including reference to Concepcion vs. Concepcion) suggested that the donation was effective as the transfer of title occurred immediately despite conditions related to the donor’s death.

Whether the four parcels (Nos. 1, 2, 3, and 10) were transferred merely as a usufruct with the residual ownership vesting in Antonio Ventenilla’s heirs or whether Alejandra Austria, as residuary legatee, held title in fee simple.
Whether the documentary and testimonial evidence establishing long possession and actual control by Alejandra Austria (and subsequently by Socorro A. Castro) established a registrable title.

Whether the donation executed on September 22, 1939, constituted a valid inter vivos donation despite conditions that deferred certain rights until after the donor’s death.
Whether the conditions attached (in particular, the reservation of usufruct for the donor’s lifetime and the obligation on the donee after the donor’s death) affected the transfer of title to Socorro A. Castro.
Whether the alleged deficiency in formalities (regarding a donation intended to be mortis causa) invalidated the donation.

Whether the earlier decision in G.R. No. L-10018, which confirmed Alejandra Austria as the residuary legatee and her possession “in concept of owner,” barred further relitigation of the title issues by the oppositors after several decades.