Case Digest (G.R. No. 212938) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Heirs of Alfredo Cullado v. Dominic V. Gutierrez (G.R. No. 212938, July 30, 2019), respondent Dominic Gutierrez secured OCT No. P-61499 over an 18,280 m² parcel in Aneg, Delfin Albano, Isabela, by patent filed May 10, 1995 and certificate issued May 17, 1995. On May 5, 1997, through his father as guardian, Dominic filed an accion publiciana in RTC Branch 22, Cabagan, seeking recovery of possession against squatter Alfredo Cullado. In his Answer, Cullado alleged open, adverse, continuous possession since 1977, claimed the land by acquisitive prescription, and counter-claimed reconveyance for fraud in Dominic’s title. Alfredo died during trial and his heirs substituted. Dominic’s counsel repeatedly failed to appear, leading the RTC on May 18, 2010 to dismiss the case and order Dominic to reconvey the disputed land to Cullado’s heirs. Dominic’s petition for relief from judgment was denied for lateness. He then sought annulment of judgment under Rule 47 before the Court of Appeal... Case Digest (G.R. No. 212938) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties
- Petitioners: Heirs of Alfredo Cullado (Lolita Cullado, Dominador Cullado, Romeo Cullado, Noel Cullado, Rebecca Lambinicio, Mary Jane Bautista, Jimmy Cullado)
- Respondent: Dominic V. Gutierrez
- Title and Possession Dispute
- May 10, 1995: Original Certificate of Title (OCT) No. P-61499 covering 18,280 m² in Aneg, Delfin Albano, Isabela issued to Dominic (then a minor).
- May 5, 1997: Action for recovery of possession (acción publiciana) filed by Dominic’s father on his behalf against Alfredo Cullado for alleged squatting since 1977.
- Cullado’s defenses: open, adverse, continuous possession and cultivation; counterclaim for reconveyance alleging fraud in Dominic’s title.
- Cullado died; his heirs substituted. Dominic’s counsel failed to appear at hearings; heirs presented evidence.
- RTC Proceedings (Civil Case No. 22-805)
- May 18, 2010: RTC rendered judgment dismissing Dominic’s complaint and ordering reconveyance of the land to the heirs of Cullado.
- March 18, 2011: Dominic’s Petition for Relief from Judgment denied as filed out of time.
- CA Proceedings (CA-G.R. SP No. 121737)
- October 18, 2011: Dominic filed petition for annulment of judgment (Rule 47) on grounds of extrinsic fraud and lack of jurisdiction; initially dismissed, then reinstated on reconsideration.
- December 6, 2013: CA granted annulment, holding RTC lacked jurisdiction to adjudicate ownership or order reconveyance in an acción publiciana (collateral attack on Torrens title).
- May 27, 2014: CA denied motion for reconsideration.
- Supreme Court Petition
- Heirs of Cullado filed a Petition for Review on Certiorari under Rule 45 seeking reversal of the CA decision.
Issues:
- Whether the Court of Appeals erred in reversing the RTC decision and granting Dominic’s petition for annulment of judgment.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)