Title
Heirs of Enriquez vs. Enriquez
Case
G.R. No. 16869
Decision Date
Mar 13, 1922
The heirs of Antonio Enriquez and Ciriaca Villanueva seek damages for the fraudulent registration and sale of their property, but the Supreme Court rules that their complaint is defective and dismisses the case due to their failure to file within the prescribed period.
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Case Digest (G.R. No. 16869)

Facts:

  • The case "Heirs of Enriquez v. Enriquez" involves the heirs of Antonio Enriquez and Ciriaca Villanueva as plaintiffs-appellants, and Francisco Enriquez and the Treasurer of the Philippine Islands as defendants-appellees.
  • A tentative partition of the estate was approved on January 25, 1906, by Judge A.S. Crossfield in the Court of First Instance of Manila.
  • Specific rights and shares in the properties were granted to Francisco Enriquez and his wife, Carmen de la Cavada.
  • A property on Calle David was fraudulently registered in the names of Francisco Enriquez and Carmen de la Cavada on January 25, 1908, without revealing existing liens and mortgages.
  • The plaintiffs-appellants were unaware of the registration application and discovered the fraudulent title two years later.
  • They filed a complaint on March 13, 1918, seeking damages for the fraudulent registration and sale of the property.
  • The lower court dismissed the case, citing the plaintiffs' negligence for not opposing the registration within the designated period.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court ruled against the plaintiffs-appellants, affirming the lower court's dismissal of the case.
  • The Court found the complaint defective due to the plaintiffs' failure to file within the prescribed period and their negligence in opposing the property registration.
  • The plaintiff...(Unlock)

Ratio:

  • The Court's reasoning was based on Act No. 496, particularly sections 38 and 107, which specify time frames for filing complaints related to land registration.
  • The plaintiffs had a one-year period to contest the registration but did no...continue reading

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