Case Digest (G.R. No. L-7495)
Facts:
Evaristo Corpuz v. Susana Corpuz, G.R. No. L-7495, September 30, 1955, the Supreme Court, Reyes, J., writing for the Court.Petitioner Evaristo Corpuz (defendant below) came into possession of an Owner's Duplicate Certificate of Title No. 5980 covering a parcel of about 1,854 square meters originally appearing in the names of Francisco Corpuz and Bernarda Mantile (deceased). By a deed dated November 12, 1934, Francisco purportedly sold the land to spouses Domingo Cruz and Eugenia Rigal for P80. The vendees had a son, Isabelo Corpuz, who married Susana Santiago (respondent). Domingo and Isabelo later died.
In 1943, after disputes between the widows Eugenia and Susana, the original certificate and other documents were entrusted to the mayor of Rizal, Nueva Ecija, but were lost during the Japanese occupation. To secure a duplicate title, Susana enlisted the help of Evaristo; he procured a duplicate in his own name and refused to turn it over, allegedly proposing litigation instead. Susana, in her capacity as judicial guardian of her minor children (heirs of the deceased Isabelo and, derivatively, of Domingo and Eugenia), filed suit for delivery of the Owner's Duplicate Certificate, a declaration that defendant had no right to possess it, and for damages and costs.
Evaristo answered, asserting the 1934 deed was fictitious or void and, alternately, that Francisco lacked authority to sell the conjugal property because his wife Bernarda died intestate in 1923 and Bernarda’s children (including Evaristo and his siblings) had inherited her one-half share. At trial the court ordered Evaristo to...(Pro-only)
Issues:
- Under the law then in force, did the sale by Francisco Corpuz convey the entire parcel or only Francisco’s share, i.e., did a surviving husband have authority to dispose of conjugal property after the death of his wife without liquidation or partition?
- Are the vendees’ heirs entitled to exclusive possession of the Owner’s Duplicate Certificate of Title, or must title be recorded in the joint names of all co-owners?
- May defendant’s claim for damages in respect of the products of the la...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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