Case Digest (G.R. No. L-12196) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Heirs of Francisco I. Narvasa, Sr. v. Imbornal, the late Basilia Imbornal owned a 4,144-sq. m. parcel in San Fabian, Pangasinan, conveyed in 1920 to her daughters Balbina, Alejandra, and Catalina. Catalina’s husband, Ciriaco Abrio, applied for and secured Homestead Patent No. 24991 over an adjacent 31,367-sq. m. riparian tract (“Motherland”) and received OCT No. 1462 in 1933, later reissued as TCT No. 101495 in the names of his heirs. Beginning in 1949, two accretions formed: the “First Accretion” (59,772 sq. m.), titled to respondent Victoriano Imbornal under OCT No. P-318 in 1952, and the “Second Accretion” (32,307 sq. m.), titled to all respondents under OCT No. 21481 in 1978. In 1984, Francisco I. Narvasa, Sr., Pedro Ferrer, and Petra Imbornal (children of Alejandra and Balbina) sued for reconveyance, partition, and damages, alleging that proceeds from the sale of the Sabangan property funded Ciriaco’s homestead application and that an implied trust arose in their favor. Case Digest (G.R. No. L-12196) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Lineage
- Basilia Imbornal had four children: Alejandra, Balbina, Catalina, and Pablo.
- Francisco I. Narvasa, Sr. and Pedro Ferrer were children of Alejandra; Petra Imbornal was daughter of Balbina. Petitioners are heirs of Francisco, Pedro, and Petra. Respondents Emiliana, Victoriano, Felipe, Mateo, Raymundo, Maria, and Eduardo are descendants of Pablo.
- Properties and Titles
- “Sabangan property” (4,144 sq. m.) conveyed by Basilia (c. 1920) to Balbina, Alejandra, and Catalina; sale proceeds allegedly funded homestead application.
- “Motherland” (31,367 sq. m.) adjacent to Cayanga River: Homestead Patent No. 24991 issued to Ciriaco Abrio; OCT No. 1462 in his name (1933); later TCT No. 101495 in heirs’ names. Northern portion occupied by Abrio heirs, southern by respondents.
- First Accretion (59,772 sq. m.) formed c. 1949; OCT No. P-318 issued to respondent Victoriano (1952), later reissued in respondents’ names.
- Second Accretion (32,307 sq. m.) formed 1971; OCT No. 21481 issued to all respondents (1978).
- Procedural History
- February 27, 1984: Petitioners filed Amended Complaint for reconveyance, partition, and damages, alleging an implied trust and fraud in registrations.
- August 20, 1996: RTC, Branch 44, Dagupan City, ruled for petitioners, finding an implied trust and ordering reconveyance and damages.
- November 28, 2006: CA in CA-G.R. CV No. 57618 reversed RTC, declaring Abrio heirs exclusive owners of the Motherland; Victoriano’s descendants owners of First Accretion; all respondents owners of Second Accretion.
- May 7, 2008: CA denied petitioners’ motion for reconsideration.
- August 6, 2014: Supreme Court received petition for review on certiorari; decision promulgated March 16, 2015 (740 Phil. 541).
Issues:
- Whether the CA erred in declaring that:
- Descendants of Ciriaco are exclusive owners of the Motherland.
- Descendants of respondent Victoriano are exclusive owners of the First Accretion.
- Descendants of Pablo (respondents) are exclusive owners of the Second Accretion.
- Whether petitioners’ claims fail on the grounds of:
- Prescription of the action for reconveyance.
- Nonexistence of an implied trust between Catalina (through Ciriaco) and the Imbornal sisters.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)