Case Digest (G.R. No. L-12573)
Facts:
On July 7, 1953, Paulina Duran initiated a legal action in the Court of First Instance of Cagayan against Bernardino Pagarigan, seeking to recover possession of a portion of land measuring one and one-half (1.5) hectares from a larger parcel of 10.1765 hectares located in Sitio Lacta, Barrio of Bangan, Municipality of Sanchez Mira, Province of Cagayan. This land had been donated to her by her deceased grandfather, Antonio Duran. Paulina alleged that Bernardino had usurped this land in December 1948, which was cultivated with approximately 130 coconut trees, generating an annual income of around P500 from the sale of its fruits. Despite her repeated demands for Bernardino to vacate the land and acknowledge her ownership, he refused to comply. Paulina sought a court order for the restoration of possession, compensation for the value of the fruits harvested by Bernardino from January 1949 until the filing of the complaint, and the payment of legal costs.
In his defense, Bernar...
Case Digest (G.R. No. L-12573)
Facts:
- Ownership Claim: Paulina Duran filed a case in the Court of First Instance of Cagayan on July 7, 1953, seeking to recover possession of 1.5 hectares of land in Sanchez Mira, Cagayan. She claimed the land was donated to her by her grandfather, Antonio Duran, and that Bernardino Pagarigan had usurped it in December 1948. The land contained 130 coconut trees yielding an annual income of P500.
- Defendant's Defense: Bernardino Pagarigan countered that he acquired the land through a verbal contract with Ignacio Duran (Paulina’s father) in 1919, later ratified in a public instrument on March 11, 1936. He also claimed that in 1936, he paid P20 to Paulina and her father to settle a prior case involving the land. He argued that Paulina’s claim was barred by the statute of limitations.
- Trial Court Findings: The trial court found that Pagarigan had been in possession of the land since 1919, acquired through an exchange with Ignacio Duran for a carabao worth P80. The court also noted that Pagarigan built a house on the land in 1936 and that the Duran family had respected his possession after the 1936 settlement. However, the court ruled that Pagarigan was occupying more land than what was covered by the deed of sale and ordered him to return the excess portion to Paulina.
- Post-Judgment Motions: Paulina filed a petition to set aside the judgment on November 30, 1954, citing fraud, mistake, and excusable neglect. The court denied her petition and subsequent motion for reconsideration, leading to her appeal to the Supreme Court.
Issue:
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Ruling:
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Ratio:
- Validity of Acquisition: A verbal contract of sale, when ratified by a public instrument and followed by continuous possession, is valid and enforceable.
- Statute of Limitations: A claimant must assert their rights within the statutory period; failure to do so bars the claim.
- Excusable Neglect: Negligence of counsel in failing to inform the client of an adverse judgment does not constitute excusable neglect sufficient to set aside a valid judgment. Notice to counsel is deemed notice to the client.