Title
Domilos vs. Spouses Pastor
Case
G.R. No. 207887
Decision Date
Mar 14, 2022
A land dispute arose from a 1986 compromise agreement dividing property among parties, later revoked. Buyers in good faith challenged revocation; SC upheld their ownership, ruling the agreement valid and execution time-barred.

Case Digest (G.R. No. 207887)
Expanded Legal Reasoning Model

Facts:

  • Acquisition and Early Possession
    • In 1953, Victoriano Domilos acquired possession of a 15,745 sq.m. parcel along Kms. 4–5, Sto. Tomas Road, Baguio City.
    • In 1974, Sergio Nabunat and family built and occupied a shanty on the land for three months.
    • In February 1976, Victoriano transferred all rights to his son, Lino Domilos. In March 1976, Nabunat and relatives, including Can-ay Palichang (mother-in-law), re-occupied and built a house without Lino’s consent.
    • Lino filed a forcible entry complaint in MTCC (formerly City Court), which, in a November 17, 1977 decision (affirmed by the RTC on January 6, 1979), ordered the removal of Nabunat’s house and restoration of possession. Execution writs were issued and the house was demolished.
  • Compromise Agreement and Subsequent Transfers
    • On November 17, 1986, Lino and Palichang executed a compromise agreement dividing the 15,000 sq.m. remainder into five portions: two shares of 3,000 sq.m. each to Lino; 3,000 sq.m. to Palichang; 3,000 sq.m. to Sergio and Soledad Nabunat; and 3,000 sq.m. to Atty. Basilio P. Rupisan.
    • From 1987 to 1989, various portions were sold, including:
      • 232 sq.m. to Dorothea L. Pastor;
      • 600 sq.m. to Joseph L. Pastor.
    • On May 9, 1989, Lino moved for issuance of a 4th alias writ of execution and, on May 15, 1989, Lino and Palichang executed a revocation of the compromise agreement. On May 20, 1989, the 4th alias writ issued, resulting in demolition of some Pastors’ improvements.
  • Annulment Suit and Procedural History
    • On June 26, 1989, the Pastors filed Civil Case No. 1784-R in the RTC, seeking annulment of the writ, revocation of the compromise-agreement cancellation, recovery of possession, damages, and injunction.
    • Lino, Palichang, and Soledad Nabunat denied material allegations; the Pastors amended to implead the judge and sheriff. The RTC admitted the amendment in 1991.
    • In 1992, Atty. Rupisan filed a separate case for joint hearing.
    • On September 21, 2006, the RTC ruled in favor of the Pastors, declaring them rightful owners of three parcels (232 sq.m., 229 sq.m., and 600 sq.m.). On January 22, 2007, the RTC denied reconsideration but modified that the Pastors “acquired lawful rights” via valid conveyance.
    • On March 26, 2013, the CA affirmed the RTC decision.
    • On March 14, 2022, the Supreme Court denied Lino’s petition for review under Rule 45, affirming the CA and RTC.

Issues:

  • Whether the RTC and CA decisions complied with Article VIII, Section 14 of the Constitution and Rule 36, Section 1 of the Rules of Court by clearly stating the facts and law.
  • Whether the compromise agreement—entered pending an RTC case and without judicial approval—constituted a valid source of right.
  • Whether the CA erred in not considering the Pastors’ judicial admissions proving they were buyers in bad faith.
  • Whether buyers in bad faith validly maintain an action to assail revocation of a compromise agreement to which they were not parties.
  • Whether Article 1131 of the Civil Code was properly applied by the CA.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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