Case Digest (G.R. No. 236173)
Facts:
Heirs of Nicanor Garcia, represented by Spouses Josefina Garcia‑Doblada and Jose V. Doblada, G.R. No. 236173, March 04, 2020, Supreme Court Second Division, Inting, J., writing for the Court.Petitioners are the heirs of Nicanor Garcia; respondents are Spouses Dominador J. Burgos and Primitiva I. Burgos, Spouses Filip Gerard V. Burgos and Marites A. Burgos, and Ester Gabriel Dominguez. Petitioners filed a Complaint for Reconveyance of Ownership, Possession and Property, Breach of Agreement/Undertaking, Cancellation of Titles, Nullity of Deeds of Sale, and Damages (Civil Case No. 325‑M‑2016) in Branch 7, Regional Trial Court (RTC), Malolos, Bulacan. They alleged that beginning in 1980 landowner Fermina Francia designated Garcia as her lawful transferee/legitimate tenant (kasama) of an 8,115 sq. m. parcel in Brgy. Daungan, Guiguinto, and that Garcia cultivated the land until his death on June 23, 2010. They alleged that about one‑third of the property (2,705 sq. m.) was later unlawfully assigned to Dominador and subdivided into six lots subsequently registered under various Transfer Certificates of Title in the names of respondents and others.
Petitioners averred that Garcia discovered the unlawful subdivision on November 24, 2008, executed a letter‑authority in favor of his nephew and Jose V. Doblada, filed a barangay complaint, and received a promise by Dominador to reconvey some lots; thereafter petitioners sent a demand letter (February 25, 2016) and, on failure to reconvey, filed the RTC complaint. Respondents denied ownership or reconveyance liability, alleged petitioners’ action was agrarian in nature (thus beyond RTC original jurisdiction), and asserted that Dominador acquired his parcels by a Deed of Absolute Sale dated February 8, 1999; Dominguez raised prescription as a defense.
At the RTC, in an Order dated January 20, 2017, the trial court denied certain affirmative defenses and maintained the pre‑trial schedule, holding there was no tenancy relationship between Dominador and Garcia that would render the dispute agrarian. Defendants moved for reconsideration. In an Order dated June 7, 2017, the RTC granted reconsideration and dismissed the complaint for lack of cause of action, lack of plaintiffs’ personality to sue, and prescription, reasoning Garcia had been only a substitute tenant (not owner) and thus his heirs could not maintain reconveyance; the court noted titles were registered in 1999 and that any action by Francia’s heirs would have prescribed after ten years. Petitioners’ motion for reconsideration was denied on November 23, 2017.
Petit...(Subscriber-Only)
Issues:
- Did petitioners avail of the proper mode of appeal in bringing their case directly to the Supreme Court by a petition for review on certiorari under Rule 45?
- Did the RTC correctly dismiss the complaint for reconveyance and r...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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