Case Digest (G.R. No. 191031) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Dolores L. Hacbang and Bernardo J. Hacbang v. Atty. Basilio H. Alo, the petitioners are grandchildren of Bishop Sofronio Hacbang’s siblings, while the respondent is the son of Bishop Sofronio’s sister, Dolores Hacbang Alo. Bishop Sofronio died on April 3, 1937, leaving a will bequeathing one‐half of his estate to his parents, Basilio and Maria Hacbang, and the other half—including Lot 8-A, Block 17, of Subdivision Plan Psd-6227, located on España Street, San Juan, Rizal—to his sister Dolores. His will was admitted to probate by the Court of First Instance of Manila on May 21, 1937, but the settlement proceedings were later archived in 1957 without adjudication of the properties. In 1971, Transfer Certificate of Title (TCT) No. 169342 covering the subject lot was issued in the name of the respondent. Dolores sought revival of the probate proceedings in 1975 but was denied. On February 1, 1999, the petitioners filed a complaint in the Quezon City RTC to cancel TCT No. 169342, a Case Digest (G.R. No. 191031) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Decedent and Testamentary Dispositions
- Bishop Sofronio Hacbang died on April 3, 1937, survived by his parents (Basilio and Maria) and siblings (Perfecto, Joaquin, Lucia Teresita, and Dolores).
- His will (Ultima Voluntad y Testamento) devised one-half of his estate to his parents and the other half to his sister Dolores, identifying specific properties including Lot 8-A, Block 17, 1,403 sqm in San Juan, Rizal (the subject lot).
- Probate, Registry and Revival Proceedings
- The will was admitted to probate by the Court of First Instance of Manila on May 21, 1937 (SP. PROC. No. 51199); the case was archived on November 2, 1957, and a motion to revive was denied on May 23, 1975.
- On September 24, 1971, TCT No. 169342 over the subject lot was issued in the name of Atty. Basilio H. Alo; its origin and relationship to prior titles remained unclear.
- Litigation on Title Cancellation
- On February 1, 1999, petitioners Dolores L. Hacbang and Bernardo J. Hacbang filed before the RTC (Civil Case No. Q-99-36660) to cancel TCT No. 169342 as fraudulently secured, supported by an LRA investigator’s report.
- The RTC dismissed the petition on January 7, 2003 for lack of standing; the CA affirmed this dismissal on October 13, 2009, and denied reconsideration on January 21, 2010. The Supreme Court granted a petition for review on certiorari.
Issues:
- Validity and Status of Title
- Whether the CA erred in not ruling on the intrinsic validity of TCT No. 169342.
- Whether the title should be canceled for alleged fraud or irregularity.
- Succession and Party-in-Interest
- Whether the probate proceedings were dismissed rather than merely archived, triggering intestate succession.
- Whether petitioners, as grandchildren of decedent’s siblings, are real parties in interest entitled to contest respondent’s title.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)