Case Digest (G.R. No. 207887) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Lino Domilos v. Spouses John and Dorothea Pastor, and Joseph L. Pastor (G.R. No. 207887, March 14, 2022), Victoriano Domilos acquired a 15,745 sqm parcel along Santo Tomas Road, Baguio City, in 1953. He transferred his rights to his son, petitioner Lino Domilos, in February 1976. Earlier occupants, Sergio Nabunat and family, built a shanty in 1974 and again erected a house in March 1976 without consent. Lino filed a forcible entry case (MTCC Civil Case No. 5893), winning in November 1977, affirmed by the RTC in January 1979, resulting in demolition of Nabunat’s house. On November 17, 1986, Lino and Can-ay Palichang executed a compromise agreement dividing the land into five 3,000 sqm shares for Domilos, Palichang, the Nabunats, Atty. Basilio Rupisan, and others. From 1987–1989, portions were sold to various buyers, including respondents Dorothea and Joseph Pastor. On May 9, 1989, Lino moved for a fourth alias writ of execution based on the 1977 decision and, on May 15, 1989, Case Digest (G.R. No. 207887) Expanded Legal Reasoning Model
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)