Case Digest (G.R. No. 139503)
Facts:
- Catalina Jandoc-Gatdula is the petitioner, representing the late Manuela Jandoc.
- Julio Dimalanta is the respondent, representing Vicenta Vda. de Natividad.
- On December 6, 1948, Manuela sold approximately 1,680 square meters of unregistered land to Vicenta Aguilar de Natividad in Dadiangas, Cotabato.
- The sale was executed through a notarized document for a consideration of P1.00 per square meter.
- Vicenta was already in possession of the property, which included her dwelling and a movie house.
- In 1958, Manuela applied for the registration of the land, including the sold property, assuring Vicenta that it would be conveyed to her.
- Original Certificate of Title No. 0-2677 was issued to Manuela on March 23, 1972.
- Vicenta demanded the conveyance, which Manuela did not fulfill, leading to Civil Case No. 1365 for specific performance in 1973.
- The Court of First Instance ruled in favor of Vicenta, but the Court of Appeals reversed this decision, which was later upheld by the Supreme Court.
- Manuela's subsequent motions for execution and possession were denied by the RTC, which stated that ownership and possession issues should be litigated appropriately.
- On October 28, 1987, Catalina filed for recovery of possession and ownership, but the RTC dismissed her complaint, declaring Dimalanta the absolute owner.
- The Court of Appeals affirmed the RTC's decision, prompting the current petition for review.
Issue:
- (Unlock)
Ruling:
- The Supreme Court ruled against the petitioner, affirming the lower courts' decisions.
- The Court found that the petitioner's rights were indeed barred by laches, denyi...(Unlock)
Ratio:
- The Court's reasoning was based on the principle of laches, which involves unreasonable delay in asserting a right, leading to a presumption of abandonment.
- The petitioner, through Manuela, had remained silent for nearly 25 years regarding the sale's validity.
- Manuela publicly acknowledged the sale and assured Vicenta of the pr...continue reading
Case Digest (G.R. No. 139503)
Facts:
The case involves Catalina Jandoc-Gatdula, as the successor-in-interest of the late Manuela Jandoc, as the petitioner, and Julio Dimalanta, as the successor-in-interest of Vicenta Vda. de Natividad, as the respondent. The events leading to this case began on December 6, 1948, when Manuela Jandoc sold a portion of unregistered land measuring approximately 1,680 square meters to Vicenta Aguilar de Natividad in Dadiangas, Buayan, Cotabato (now General Santos City). The sale was executed through a notarized document by Justice of the Peace Gavino Yapdiongco. Vicenta was already in possession of the property, where her dwelling and a movie house were located, and the sale was made for a consideration of P1.00 per square meter.
In 1958, Manuela applied for the registration of three parcels of land, including the property sold to Vicenta, under Land Registration Case No. N-78. To expedite the registration, Manuela persuaded Vicenta not to oppose the application, assuring her that the property would be conveyed to her. On March 23, 1972, Original Certificate of Title No. 0-2677 was issued to Manuela. However, Vicenta demanded the conveyance, which Manuela failed to honor, leading Vicenta to file Civil Case No. 1365 for specific performance in 1973. The Court of First Instance ruled in favor of Vicenta, ordering Manuela to execute a registrable document in her favor. This decision was appealed, and the Court of Appeals reversed the ruling, dismissing Vicenta's complaint. The Supreme Court later denied Vicenta's appeal, making the appellate court's decision final.
Subsequently, Manuela filed an Omnibus Motion for a Writ of Execution and a Writ of Possession, which was denied by the Regional Trial Court (RTC) of G...