Case Digest (G.R. No. L-13876) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Consolacion Florentino de Crisologo, et al. v. Dr. Manuel Singson (114 Phil. 410; 61 OG 4248, July 1965; G.R. No. L-13876, February 28, 1962 under the 1935 Philippine Constitution), spouses Consolacion Florentino de Crisologo and Francisco Crisologo (plaintiffs-appellees) filed an action for partition against Dr. Manuel Singson (defendant-appellant) over a residential lot (Tax No. 10765-C) of approximately 193 square meters with improvements, situated on Plaridel Street, Vigan, Ilocos Sur. Plaintiffs alleged that the lot was owned pro indiviso in equal halves: one half by Singson, and the other half by Consolacion Florentino through the duly probated last will of their aunt, Doña Leona Singson, original owner. That will had been probated in Special Proceeding No. 453 before the Court of First Instance of Ilocos Sur and affirmed by the Court of Appeals in G.R. No. 3605-R. Plaintiffs demanded partition, but the defendant refused, prompting the present suit. Singson contended th Case Digest (G.R. No. L-13876) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Property
- Plaintiffs-Appellees: Spouses Consolacion Florentino and Francisco Crisologo.
- Defendant-Appellant: Dr. Manuel Singson.
- Subject Matter: A residential lot (approx. 193 sqm) and improvements at Plaridel St., Vigan, Ilocos Sur, Tax No. 10765-C, alleged to be owned pro-indiviso one-half by Singson and one-half by Florentino under the probated will of Dona Leona Singson.
- Procedural History
- Complaint filed for partition alleging refusal by defendant to divide the property despite valid demands.
- Defendant’s defense: Consolacion Florentino held only usufructuary rights, not ownership, and thus lacked the right to demand partition.
- Trial Court Decision: Declared the parties co-owners (undivided one-half each), ordered them to partition within 30 days or by court commissioners; appealed by Singson.
- Testamentary Background
- Original Owner: Dona Leona Singson, died January 13, 1948, single; will executed July 31, 1951, probated in Special Proceeding No. 453, affirmed by Court of Appeals.
- Clause IX of Will (“Noveno”): Bequeathed half of her house and lot to her granddaughter Consolacion Florentino, “but if she dies before or after me, this property shall be given equally to my brothers Evaristo, Manuel, and Dionisio, or their forced heirs.”
Issues:
- Whether the testamentary clause in Clause IX constituted a sustitución vulgar (ordinary substitution) or a sustitución fideicomisaria (fideicommissary substitution).
- Whether Consolacion Florentino acquired full ownership (and thus the right to demand partition) or only usufructuary rights over one-half of the property.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)