Title
Supreme Court
Ilocos Norte Electric Cooperative vs. Cynthia Gertrudes Andres-Ranjo, Elma Andres Maraaan, represented by William G. Maraaan
Case
G.R. No. 200544
Decision Date
Aug 17, 2022
Dispute over 10,000 sq.m. land claimed by Delfino Andres and INEC; SC upheld Andres' 1957 purchase, annulled 1998 compromise, awarded 2/3 to heirs.

Case Digest (G.R. No. 85934)
Expanded Legal Reasoning Model

Facts:

Origins of the Case The case began with a complaint filed by Delfino Andres on October 12, 1992, against Concepcion Segundo and Ilocos Norte Electric Cooperative (INEC) for ownership of a 10,000 square meter (sq.m.) portion of Lot No. 23315. Delfino claimed he purchased the land from Felipa Segundo Ruiz in 1957 and had been in possession until INEC began developing the property.

INEC’s Defense
Concepcion, representing her late husband Nemesio Segundo, argued that she sold an 8,000 sq.m. portion of her share in Lot No. 23315 to INEC in 1991. INEC maintained it purchased the land in good faith and that it differed from the land claimed by Delfino.

Board of Commissioners and Ocular Inspections
A Board of Commissioners, aided by Geodetic Engineer Florencio C. Gamiao, found discrepancies in the property descriptions provided by both parties. However, during a second ocular inspection, the parties identified the same parcel of land, leading Engineer Gamiao to conclude they were claiming the same property.

Compromise Agreement and Annulment
After Delfino’s death, his son Neil Benjamin Andres entered into a compromise agreement with INEC in 1998, which was approved by the RTC in 1999. However, Delfino’s adopted daughters, Cynthia Gertrudes Andres-Ranjo and Elma Andres MaraAon, successfully petitioned the CA to annul the compromise agreement, arguing it deprived them of their inheritance.

RTC and CA Decisions
The RTC declared the Andres sisters owners of two-thirds (2/3) of the southeastern portion of Lot No. 23315. The CA upheld this decision but deleted the award of attorney’s fees. INEC appealed to the Supreme Court, citing a 2003 RTC decision in a cadastral case confirming its title to the property.

Issues:

  • Identity of the Subject Property: Whether the parcels of land claimed by the parties are the same.
  • Ownership of the Subject Property: Whether Delfino or INEC has a better right over the land.
  • Validity and Effect of the Compromise Agreement: Whether the compromise agreement between INEC and Neil affected the Andres sisters’ rights.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

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