Case Digest (G.R. No. 176464) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In AURORA DEL BANCO, ET AL. v. INTERMEDIATE APPELLATE COURT, G.R. No. 72694, decided on December 1, 1987 under the 1987 Philippine Constitution, the petitioners—Aurora and Evelyn del Banco, Federico, Soledad, Jovencio, Samson, Noe, Socorro and Cleofas Taino—sought review of the Court of Appeals’ May 17, 1985 decision (AC‐G.R. CV No. 70460) and its October 15, 1985 resolution, which had reversed the trial court’s November 6, 1981 dismissal of a Rule 69 special civil action for partition. The dispute concerned Cagbalite Island in Mauban, Quezon, originally purchased in 1859 by the Pansacola brothers—Benedicto, Jose and Manuel (Fr. Manuel Peña)—and their minors represented co‐owners, with benefit‐sharing proportions revised by agreement on April 11, 1868. No physical partition was effected. In 1907 and 1908, heirs and successors (including Domingo Arce and Baldomera Angulo) agreed pro indiviso on a subdivision scheme and commissioned surveys, which were never implemented for lack o Case Digest (G.R. No. 176464) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Antecedent Agreements and Co-ownership
- In 1859, brothers Benedicto Pansacola, Jose Pansacola and Manuel Pansacola (Fr. Manuel Peña), together with minor heirs Domingo Arce and Baldomero Angulo (represented by Manuel), executed an agreement to purchase Cagbalite Island (≈1,600 ha) from the Spanish Government as common property, sharing benefits in proportions: Benedicto ¼, Jose ¼, Domingo & Baldomero (via Manuel) ½.
- On April 11, 1868, the co-owners modified their agreement to include additional heirs: Eustaquio Pansacola’s children (Mariano, Maria, Hipolito) allotted ¼, and Manuel’s nephews/nieces (Domingo Arce, Baldomera Angulo, Marcelina Flores, Francisca Flores, Candelaria de la Cruz, Gervasio Pansacola) allotted ¼.
- Judicial Proceedings
- On November 18, 1968, private respondents filed a special partition action under Rule 69, including all heirs and successors of the April 11, 1868 co-ownership agreement. Defendants (petitioners) pleaded prescription, res judicata, exclusive ownership, estoppel and laches.
- Trial Court (Nov. 6, 1981) dismissed the complaint, finding the island already partitioned into four parts. Petition for reconsideration was denied. The Court of Appeals (May 17, 1985) reversed, declared the property co-owned, ordered cancellation of titles and judicial partition. Petitioners sought certiorari in the Supreme Court on December 5, 1985, leading to consolidated pleadings and memoranda.
Issues:
- Whether Cagbalite Island remains undivided common property owned by the heirs and successors-in-interest of Benedicto, Jose and Manuel Pansacola.
- Whether prior Supreme Court decisions in G.R. Nos. 21033–35 on an “abstract partition” operate as res judicata to bar the present partition action.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)