Case Digest (G.R. No. 188773)
Facts:
Heirs of Valentin Basbas, et al. v. Ricardo Talampas Basbas, G.R. No. 188773, September 10, 2014, First Division, Perez, J., writing for the Court. Petitioners are the Heirs of Valentin Basbas (hereinafter petitioners); respondent is Ricardo Talampas Basbas (hereinafter respondent), who together with Crispiniano Basbas had title to the subject lot. The petition is a Rule 45 petition for review on certiorari seeking reversal of the Court of Appeals decision in CA-G.R. SP No. 99853 which set aside the judgments of the Municipal Trial Court (MTC), Santa Rosa, Laguna and the Regional Trial Court (RTC), Branch 24, Biñan, Laguna, in Civil Case No. 1913 and Civil Case No. B-6334, respectively.The underlying action (MTC Civil Case No. 1913) was an action for annulment of title and reconveyance filed by petitioners to annul TCT No. T-294295 (covering Lot No. 39, Santa Rosa Detached Estate) issued in the names of Crispiniano and Ricardo and to recover possession. Petitioners and respondent each trace title back to Severo Basbas, the original certificate-holder under Certificate of Title No. RT-1684 (N.A.). Respondents countered that after Severo’s death the estate was divided between his sons Valentin and Nicolas, that Lot No. 39 passed to Nicolas and thence to his descendants (including Crispiniano and Ricardo), and that they had lawfully reconstituted and retitled Lot No. 39 in their names.
During trial both sides introduced documentary and testimonial evidence including (1) Certificate of Title No. RT-1684 (N.A.) in Severo’s name; (2) RTC Order (LRC B-758) dated June 1, 1989 granting a petition for reconstitution of title filed by Crispiniano and Ricardo; (3) TCT No. T-294295 issued to Crispiniano and Ricardo; and (4) an Extra-Judicial Settlement of Estate of Severo executed by Crispiniano and Ricardo. The MTC made a stipulation of facts (Pre-Trial Order, 2 September 1998) that acknowledged, inter alia, that: Severo was married to Ana Rivera; petitioners are direct descendants of Valentin (Severo’s son); and the disputed property was originally registered in Severo’s name.
After trial the MTC found petitioners proved their filiation from Severo (via Valentin) and declared TCT No. T-294295 null and void, ordered reconveyance to petitioners and directed issuance of a new title in favor of the heirs of Severo. The RTC, on appeal (Civil Case No. B-6334), affirmed the MTC in toto. Crispiniano and Ricardo then appealed to the Court of Appeals.
The Court of Appeals reversed, relying on Heirs of Guido and Isabel Yaptinchay v. Del Rosario, holding that questions of filiation and heirship must be resolved in a special probate proceeding and t...(Subscriber-Only)
Issues:
- Did the Court of Appeals err in reversing and setting aside the RTC and MTC decisions that found for petitioners?
- Was the Court of Appeals correct in applying Heirs of Yaptinchay v. Del Rosario to require a prior probate proceeding to determine heirship before resolving the annulment of title and reconveyance action?
- Did the Court of Appeals err in failing to render judgment on the evidence presented ...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)