Case Digest (G.R. No. 138945) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In G.R. No. 138945, Felix Gochan and Sons Realty Corporation and Sta. Lucia Realty and Development Corporation vs. Heirs of Raymundo Baba, decided on August 19, 2003 under the 1987 Constitution, Lot No. 3537—a 6,326 sqm conjugal property of spouses Raymundo Baba (d. 1947) and Dorotea Inot—was the subject of an extrajudicial settlement dated December 8, 1966, among Dorotea and two of Raymundo’s children, Victoriano and Gregorio Baba. Under that settlement, Dorotea received one-half of the lot; Victoriano and Gregorio divided the other half. On December 28, 1966, these three vendors sold the entire parcel to petitioner Felix Gochan and Sons Realty Corporation for ₱2,346.70, prompting the cancellation of OCT No. RO-0820 and the issuance on February 23, 1968 of TCT No. T-1842 in favor of Gochan Realty. In 1995, Gochan Realty entered a joint venture with Sta. Lucia Realty for subdivision development of Lot No. 3537. On June 13, 1996, respondents Bestra, Maricel, Cresencia, Antonio an Case Digest (G.R. No. 138945) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Property
- Petitioners
- Felix Gochan and Sons Realty Corporation (purchaser and registered owner of Lot No. 3537).
- Sta. Lucia Realty and Development Corporation (joint-venture partner in subdivision development).
- Respondents
- Heirs of Raymundo Baba (Bestra, Maricel, Cresencia, Antonio, Petronila), represented by attorney-in-fact Virginia Sumalinog; allege co-heirs of spouses Raymundo Baba and Dorotea Inot.
- Disputed Property
- Lot No. 3537 (6,326 sq.m.), originally titled under OCT No. RO-0820 in Dorotea’s name as conjugal property.
- Transactional and Procedural History
- 1947–1968 Transactions
- 1966: Extrajudicial settlement among Dorotea, Victoriano Baba and Gregorio Baba; half undivided share to Dorotea, remainder to Victoriano and Gregorio.
- 28 December 1966: Deed of sale of entire lot to Gochan Realty for ₱2,346.70; 23 February 1968: TCT No. T-1842 issued in its favor.
- 1995–1999 Proceedings
- 1995: Gochan Realty enters joint-venture with Sta. Lucia for subdivision.
- 13 June 1996: Respondents file complaint for quieting of title and reconveyance with damages (Civil Case No. 4494-L, RTC Lapu-Lapu City), alleging lack of consent to the 1966 settlement and sale.
- RTC: Gochan Realty pleads lack of personality, prescription (10 years), laches, estoppel, good-faith purchaser; Sta. Lucia in default.
- 3 May 1997: RTC dismisses complaint for prescription and laches (action treated as implied trust, prescriptible in 10 years).
- Court of Appeals reverses and reinstates complaint, holding possession by respondents bars prescription and laches; motion for reconsideration denied 25 May 1999.
- 19 August 2003: SC grants petition for review on certiorari, sole issue—whether the complaint is dismissible for prescription and laches.
Issues:
- Prescription
- Is respondents’ action barred by the ten-year prescription applicable to obligations created by law (implied or constructive trust) from issuance of the certificate of title?
- Does respondents’ possession of the property prevent the application of prescription?
- Laches
- Does respondents’ delay in asserting their rights constitute laches, thereby barring an otherwise imprescriptible cause of action?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)