Case Digest (G.R. No. 211153) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Amparo S. Cruz et al. v. Angelito S. Cruz et al. (G.R. No. 211153, February 28, 2018), petitioners Amparo S. Cruz and Antonia Cruz (deceased, represented by heirs Halili et al.) and respondents Angelito S. Cruz, Concepcion S. Cruz, Serafin S. Cruz, and Vicente S. Cruz inherited a 940-sqm property covered by Original Certificate of Title No. ON-658 from their parents. On July 31, 1986, the siblings executed a deed of extrajudicial settlement agreeing to equal shares. In 1998, during subdivision proceedings, respondents discovered that Antonia had been allotted two lots while each of the other heirs received one. Concepcion, who had only elementary education and did not understand English, alleged that she was fraudulently induced by Amparo and Antonia to sign the English-language deed without explanation. She filed an Amended Complaint on April 6, 1999 (Civil Case No. 1380-98 SM, RTC San Mateo, Rizal), seeking nullification of the settlement, inclusion of one of Antonia’s lots Case Digest (G.R. No. 211153) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Subject Property
- Petitioners: Ernesto Halili, Alicia H. Florencio, Donald Halili, Editha H. Rivera, Ernesto Halili, Jr., and Julito Halili (heirs of Antonia Cruz).
- Respondents: Angelito S. Cruz, Concepcion S. Cruz, Serafin S. Cruz, and Vicente S. Cruz (co-heirs of Felix and Felisa Cruz).
- Property: A 940-square-meter parcel covered by Original Certificate of Title No. ON-658, inherited from deceased parents.
- Execution of Extrajudicial Settlement and Alleged Irregularity
- On July 31, 1986, all heirs executed an extrajudicial settlement of estate in English, ostensibly allocating equal shares of the subject property.
- In 1998, during subdivision, respondents discovered that Antonia’s share comprised two lots, while each other co-heir received only one lot.
- Respondents alleged that Concepcion (elementary grade school graduate, illiterate in English) was induced by Amparo and Antonia to sign the English-language deed without explanation, resulting in an unequal share.
- Procedural History
- April 6, 1999 – Respondents filed an Amended Complaint (Civil Case No. 1380-98 SM, RTC San Mateo, Rizal) praying to:
- Declare the July 31, 1986 extrajudicial settlement null and void;
- Return one of Antonia’s two lots to the common fund;
- Grant just and equitable relief;
- Award costs.
- June 1, 2010 – RTC dismissed the complaint for failure to prove fraud, misrepresentation, or mistake by clear and convincing evidence; held action not barred by prescription but lacked specific fraud allegations.
- June 25, 2013 – Court of Appeals reversed, annulling the extrajudicial settlement on ground that Concepcion’s consent was vitiated under Civil Code Art. 1332; held the four-year prescriptive period for annulment had not yet lapsed.
- January 29, 2014 – CA denied petitioners’ motion for reconsideration.
- February 28, 2018 – Supreme Court denied the Petition for Review on Certiorari, declared the settlement null and void on ground of total nullity and imprescriptibility of action.
Issues:
- Has the action to annul the July 31, 1986 extrajudicial settlement prescribed?
- Was Concepcion’s consent to the settlement vitiated by mistake or fraud under Civil Code Art. 1332?
- Does exclusion of an heir render an extrajudicial settlement a total nullity, thus making any challenge imprescriptible?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)