Case Digest (G.R. No. 217365)
Facts:
Heirs of Satramdas v. Sadhwani, G.R. No. 217365, August 14, 2019, Supreme Court Second Division, Caguioa, J., writing for the Court. The petitioners are the legitimate children and heirs of the late spouses Satramdas V. Sadhwani and Kishnibai S. S. Sadhwani; respondents are their brother Gop S. Sadhwani, his wife Kanta G. Sadhwani, Union Bank of the Philippines, Philippine Savings Bank, and the Register of Deeds of Makati.The dispute concerns ownership of two parcels: a house and lot at 58 Aries St., Bel Air, Makati (the Bel Air Property) and Condominium Unit 602‑A at the Ritz Tower, Ayala Avenue, Makati City (the Ritz Condominium Unit). Petitioners allege the properties were purchased by the spouses Sadhwani and titled in the name of their son Gop in trust for the parents and siblings. On November 13, 2013, petitioners filed a Complaint for Reconveyance, Partition, Accounting, Declaration of Nullity of Documents, Injunction and Damages with prayer for preliminary relief against Gop, Kanta, the banks and the Register of Deeds, asserting rights as heirs and beneficiaries under an alleged express trust and succession law.
Respondents filed motions to dismiss (filed November 27, 2013) raising prescription, lack of legal capacity to sue, and failure to state a cause of action; Union Bank also moved to dismiss while PSB answered. Petitioners filed an amended complaint on March 11, 2014 after the Bel Air Property was sold to Sefuel Siy Yap. The Regional Trial Court (RTC), Makati City, Branch 59, granted the motions and dismissed the Complaint by Resolution dated January 6, 2015, and denied reconsideration in its March 18, 2015 Order. The RTC found from attached death certificates that the spouses Sadhwani were Indian nationals and therefore, under Article XII, Section 7 of the 1987 Constitution, were prohibited from owning private lands and could not transmit rights by succession; the dismissal was grounded on lack of personality and that the Complaint stated no cause of action.
Petitioners filed a petition for review on certiorari under Rule 45 of the Rules of Court raising, inter alia, that the RTC erred in finding lack of capacity and in dismissing for failure to state a cause of action and that they assert rights as beneficiaries of a resulting trust. Respondents opposed the petition, arguing among other points that petitioners sought the wrong remedy (raising questions of fact unsuitable for Rule 45), that the Complaint fa...(Subscriber-Only)
Issues:
- Did petitioners avail of the correct remedy to challenge the RTC's dismissal of the Complaint?
- Was the Complaint properly dismissed for failure to state a cause of action and relate...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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