Case Digest (G.R. No. 150179) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Heirs of William Sevilla et al. v. Leopoldo Sevilla et al. (450 Phil. 598, April 30, 2003), eight children of the late Filomena Almirol de Sevilla inherited four parcels of land in Dipolog City. Among these heirs were petitioners Wilfredo, Wilson, Wilma, Willington and William Jr. (Heirs of William), Amador, Jeno, Victor, Maricel, Alelei and Anjei (Heirs of Maria), Rosa and Felipe Sevilla, and respondents Leopoldo, Peter and Luzvilla Sevilla. Parcel I (Lot 653) was Filomena’s paraphernal property, co-owned with her unmarried sisters Honorata and Felisa. Upon Honorata’s death in 1982, her one-third share passed to Felisa and the heirs of Filomena, making Felisa owner of one-half interest in Lot 653. Felisa executed a will (1985) and a Donation Inter Vivos (August 8, 1986) conveying her one-half share to Leopoldo, and joined Peter (for other heirs) in an Extrajudicial Partition (September 3, 1986). In June 1990, dissatisfied heirs filed for annulment of the donation and partiti Case Digest (G.R. No. 150179) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Succession and properties
- On December 10, 1973, Filomena Almirol de Sevilla died intestate, survived by eight children: William, Peter, Leopoldo, Felipe, Rosa, Maria, Luzvilla, and Jimmy Sevilla (William, Jimmy, and Maria later died, leaving their heirs).
- Filomena’s estate comprised:
- Parcel I – Lot No. 653 (804 m²; paraphernal property co-owned with sisters Honorata and Felisa) with commercial and residential buildings.
- Parcel II – Lot No. 3805-B (18,934 m²; conjugal property).
- Parcel III – Lot No. 837-1/4 (880 m²; conjugal property).
- Parcel IV – Lot No. 1106-B-3 (300 m²; conjugal property).
- Title transmissions and challenged instruments
- 1982: On Honorata’s death, her 1/3 undivided share in Lot 653 passed to Felisa and the heirs of Filomena (each acquiring a 1/2 share).
- November 25, 1985: Felisa executed a will devising her 1/2 share in Lot 653 to Leopoldo Sevilla and spouse Belen Leyson.
- August 8, 1986: Felisa executed a Deed of Donation inter vivos ceding her 1/2 share in Lot 653 to Leopoldo (accepted in the same document).
- September 3, 1986: Felisa and Peter Sevilla executed a Deed of Extrajudicial Partition of Honorata’s former share, adjudicating portions among Felisa and Filomena’s heirs.
- Respondents obtained cancellation of the TCT over Lot 653 and applied for new titles to Felisa and Filomena’s heirs; issuance was held pending a special power of attorney.
- Judicial proceedings
- June 21, 1990: Felipe, Rosa, and the heirs of William, Jimmy, and Maria filed suit against Leopoldo, Peter, and Luzvilla for:
- Annulment of the Deed of Donation and the Deed of Extrajudicial Partition (alleging fraud, undue influence, and lack of consent).
- Accounting, damages, receivership, and partition of all four parcels.
- December 16, 1994: RTC Dipolog City, Branch 6 rendered judgment:
- Declared the Deed of Donation valid and binding.
- Declared the Deed of Extrajudicial Partition unenforceable for lack of participation by all heirs.
- Ordered partition of Parcels II–IV equally; Parcel I to be divided in two between Leopoldo and collectively the other heirs, with accounting.
- September 26, 2000: Court of Appeals affirmed the RTC decision in toto.
- August 30, 2001: CA denied petitioners’ motion for reconsideration.
- Petitioners elevated the case to the Supreme Court, assigning errors:
- That the Deed of Donation was void ab initio for fraud, undue pressure, and influence.
- That Lot 653 should be partitioned equally among all eight Almirol heirs.
Issues:
- Whether the Deed of Donation inter vivos by Felisa Almirol in favor of Leopoldo Sevilla is void for fraud and undue influence.
- Whether the Deed of Extrajudicial Partition executed without participation or authorization of all heirs is enforceable.
- How Lot No. 653 should be finally partitioned among the heirs.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)