Case Digest (G.R. No. 262975)
Facts:
The case involves multiple petitions related to property disputes stemming from a parcel of land owned by the late spouses Juan Ramos and Fortunata Calibo. After their deaths intestate, the property was passed down to their heirs, including two daughters, Candida and Victoriana Ramos, as well as granddaughter Agapita Ramos. Over time, several transactions occurred involving the properties known as the Talon and Laong properties, which were subjected to various sales, partitions, and registrations stemming from actions taken by the heirs. The original complaint was filed on June 14, 1963, by the respondents at the Court of First Instance of Rizal, seeking recovery and partition of these properties. Following amendments to include critical information and parties, the trial court ruled on April 12, 1975, declaring plaintiffs entitled to certain shares, though some properties had been validly sold to third parties acted in good faith. Both parties appealed decisions that were laterCase Digest (G.R. No. 262975)
Facts:
- Background of the Case
- The consolidated petitions arose from a complaint filed on June 14, 1963 before the Court of First Instance of Rizal, Branch VII, Pasay City, for the recovery and partition of two parcels of land owned by deceased spouses Juan Ramos and Fortunata Calibo.
- After the spouses died intestate, their properties automatically devolved upon their heirs.
- The heirs from their legitimate children were Candida Ramos, Victoriana Ramos, and Agapita Ramos (the granddaughter, daughter of the deceased son Anastacio).
- The properties remained co-owned pro-indiviso by these heirs until subsequent sales, partitions, and subdivisions.
- Description of the Properties
- Talon Property
- Located in Barrio Talon, with an area of 39,887 square meters as per Tax Declaration No. 9614.
- A portion was sold in 1943 by Candida Ramos, Eulogio Bandin, and Agapita Ramos to effect a division, which was later subdivided into three distinct parcels.
- Subsequent transactions included sales to the spouses Rufino O. Miranda and Natividad Guinto, from whom the property passed through several hands (including Narciso Velasquez, Albino Miranda, and Velasquez Realty Company, Inc.) and through extrajudicial partitions among the heirs.
- Laong Property
- Located in Barrio Laong, originally declared at 15,993 square meters (with a surveyed actual area of 22,288 square meters) under Tax Declaration No. 4005.
- Sold on December 19, 1943 by Candida Ramos and her children to Hermogenes Lucena (husband of Juanita Martin, one of Candida’s daughters).
- This property later became the subject of disputes when a portion measuring 15,000 square meters was conveyed to spouses Felipe and Antonia David in January 1965 through a deed also signed by Juanita Martin.
- History of Transactions and Lower Court Proceedings
- The trial court, on April 12, 1975, issued a decision in favor of the plaintiffs by declaring that:
- The Talon and Laong properties formed part of the deceased spouses’ estate and were owned pro-indiviso by the heirs, each being entitled to one‑third share.
- The heirs of Victoriana Ramos and Agapita Ramos were entitled to two‑thirds (2/3) of the properties, with an order for the other heirs (those of Candida Ramos) to reconvey their shares.
- Reconveyance, however, was impracticable for the portions that had already been sold to third parties who were purportedly purchasers in good faith.
- On appeal, the Court of Appeals:
- Modified the trial court’s decision by nullifying certain transfers and sales affecting the disputed shares.
- Specifically:
- Nullified the sale and subsequent transactions of the Laong property affecting Agapita Ramos and heirs of Victoriana Ramos.
- Nullified the sale of certain portions of the Talon property affecting the four‑fifteenth (4/15) share belonging to Gregorio Bandin, Raymunda Bandin, Valentin Briones, and Sofio Briones.
- Declared the extrajudicial partition of the remaining Talon property and its subdivision among the heirs of Candida Ramos void with respect to the 2/3 share of Agapita Ramos and the heirs of Victoriana Ramos.
- The Separate Petitions and Key Parties
- G.R. No. L‑49716 (Heirs of Candida Ramos)
- Petitioners contended that respondents’ claims were barred by prescription and invoked res judicata due to the finality of previous registration decrees.
- They argued that possession and administration of the Laong property by Juanita Martin since 1943 negated any adverse claims of prescription.
- G.R. No. L‑48322 (Spouses Felipe David and Antonia G. David)
- Petitioners purchased portions of the Laong property in 1965 when the land was still unregistered and later became affected by the subsequent issuance of a Torrens title in 1971.
- They contended that they were buyers in good faith, contending doctrines regarding incontrovertibility and conclusiveness.
- G.R. No. L‑49867 (Jose Ramirez and Heirs of Ambrocia P. Vda. de Ramirez)
- Petitioners purchased parcels (one of approximately 752 square meters and another of 516 square meters) which were part of the Talon property transferred earlier in 1943.
- The issue centered on whether they were bona fide purchasers when relying merely on tax declarations presented by the seller.
- G.R. No. L‑49712 (Magno de la Cruz)
- Petitioner Magno de la Cruz purchased property from Victoria Martin and Maximina Martin, which had already been registered and covered by a valid Torrens title.
- His contention rested on his status as a purchaser in good faith for value, thereby seeking to validate the deeds and title issued in his favor.
Issues:
- Whether the defense of prescription applied effectively to bar the claim of the co-heirs and whether the prescription period was tolled by the conduct of the parties.
- Analysis of Article 494 of the new Civil Code (old Article 400) and the absence of any repudiation of co-ownership rights by Candida Ramos.
- The applicability of the doctrine of res judicata as invoked by petitioners in G.R. No. L‑49716 regarding the decree of registration of property.
- Whether a decree issued and later affirmed (OCT No. 8916) could conclusively vest title in the absence of all pertinent parties.
- Whether the status of the property as unregistered land at the time of sale affects the protection accorded to alleged purchasers in good faith.
- Contrast between purchasers who acquire registered land versus those who purchase unregistered land.
- Whether the court should validate and protect the rights of Magno de la Cruz as a bona fide purchaser under the Torrens system.
- The significance of actual notice and reliance on clean title in establishing good faith.
- The proper remedy for respondents concerning the recovery of their pro-indiviso share from the parties who sold or conveyed interests in the disputed properties.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)