Case Digest (G.R. No. 217365) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Heirs of Satramdas v. Sadhwani, the petitioners, legitimate children of the late Spouses Satramdas and Kishnibai Sadhwani, sought recognition of their ownership over two properties—a house and lot in Bel Air, Makati, and Condominium Unit 602-A at the Ritz Tower—allegedly purchased by their parents but titled in the name of their brother, respondent Gop S. Sadhwani, “in trust” for the family. On November 13, 2013, the petitioners filed a Complaint for Reconveyance, Partition, Accounting, Declaration of Nullity of Documents, Injunction and Damages against Gop and his wife Kanta, Union Bank of the Philippines, Philippine Savings Bank, and the Register of Deeds of Makati City. They anchored their claim on an express trust agreement and the Civil Code provisions on succession. Respondents moved to dismiss on grounds of prescription, lack of capacity to sue, and failure to state a cause of action. On January 6 and March 18, 2015, the Regional Trial Court of Makati (Branch 59) grant Case Digest (G.R. No. 217365) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Subject Properties and Alleged Trust Arrangement
- The dispute involves a parcel of land at 58 Aries St., Bel Air II Village, Makati City (Bel Air Property) and Condominium Unit 602-A at the Ritz Tower, Ayala Avenue, Makati City (Ritz Condominium Unit).
- The Spouses Satramdas and Kishnibai S. Sadhwani, both Indian nationals, allegedly purchased the subject properties and placed the land titles in the name of their son, respondent Gop S. Sadhwani, to hold in trust for themselves and their children.
- Complaint for Reconveyance and Trial Court Proceedings
- On November 13, 2013, heirs Ramchand S., Drupati Mirpuri, Haresh S., Gop S., and Rajan S. Sadhwani (petitioners) filed a Complaint for Reconveyance, Partition, Accounting, Declaration of Nullity of Documents, Injunction, and Damages against respondents Gop and his wife Kanta, Union Bank of the Philippines (Union Bank), Philippine Savings Bank (PSB), and Register of Deeds of Makati City. They prayed to be declared lawful owners of the subject properties under a purported express trust and the Civil Code’s succession provisions.
- Respondents Gop and Kanta moved to dismiss on grounds of prescription, lack of legal capacity to sue, and failure to state a cause of action. Union Bank also moved to dismiss; PSB filed an answer. Petitioners later filed an amended complaint following a sale of the Bel Air Property.
- RTC Dismissals and Petition for Review
- On January 6 and March 18, 2015, RTC Makati City Branch 59 granted the motions to dismiss, finding:
- Petitioners sued as heirs of Indian nationals prohibited by Article XII, Section 7 of the 1987 Constitution from owning or transmitting private lands.
- The complaint stated no cause of action or legal capacity to sue.
- Petitioners sought review under Rule 45 before the Supreme Court, arguing the RTC erred in holding there was no cause of action, no personality to sue, and that they used the wrong theory (beneficiaries of resulting trust).
Issues:
- Correctness of Remedy Employed
- Whether petitioners properly availed of a petition for review on certiorari under Rule 45 to challenge the RTC’s dismissal without prejudice.
- Whether the hierarchy of courts and appealability rules were observed.
- Validity of Trial Court’s Dismissal
- Whether the RTC correctly dismissed the complaint for failure to state a cause of action based on the parents’ status as Indian nationals.
- Whether petitioners had legal capacity and a sufficiently pleaded cause of action to maintain the claims.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)