Case Digest (G.R. No. 154486) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In G.R. No. 154486, decided on December 1, 2010 under the 1987 Constitution, the petitioner, Federico Jarantilla, Jr., grandson of the late spouses Andres Jarantilla and Felisa Jaleco, sought review of the Court of Appeals’ July 30, 2002 decision on CA-G.R. CV No. 40887. The respondent, Antonieta Jarantilla, aunt of the petitioner and one of eight children of the Jarantilla spouses, had filed on April 22, 1987 before the Regional Trial Court (RTC) of Quezon City, Branch 98 (Civil Case No. Q-50464), an amended complaint for accounting, partition and delivery of an 8% share in certain businesses and real properties, as well as damages and attorney’s fees. She alleged that, beginning in 1946, she and her siblings and spouses—including Conchita Jarantilla and her husband, Buenaventura Remotigue—had entered into an unregistered and verbal partnership which was later confirmed in a notarized Acknowledgement of Participating Capital dated April 29, 1957 listing the participating capita Case Digest (G.R. No. 154486) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Background
- Andres Jarantilla and Felisa Jaleco had eight children: Federico Sr., Delfin, Benjamin, Conchita, Rosita, Pacita, Rafael and Antonieta.
- Petitioner Federico Jarantilla, Jr. is the grandson of Andres and Felisa; his brothers are Doroteo and Tomas. Respondents include his aunt Antonieta Jarantilla, Conchita’s husband Buenaventura Remotigue (succeeded by adopted daughter Cynthia Remotigue), and his brothers Doroteo and Tomas.
- Extrajudicial Partition and Business Arrangement
- In 1948, the Jarantilla heirs extrajudicially partitioned their parents’ real properties and agreed to allot produce (1947–1949) for the studies of Rafael and Antonieta.
- Also in 1948, spouses Rosita Jarantilla-Deocampo and Vivencio Deocampo entered a joint business arrangement with Buenaventura Remotigue and Conchita Jarantilla, resulting in successful enterprises and property acquisitions.
- Dissolution and Acknowledgement of Capital
- The partnership was dissolved by agreement in 1973.
- On April 29, 1957, Buenaventura and Conchita Remotigue executed an “Acknowledgement of Participating Capital,” listing seven co-owners and their capital contributions in Manila Athletic Supply and Remotigue Trading (Iloilo, Cotabato), including Antonieta (8%) and Federico Jr. (6%).
- Trial Court Proceedings
- On April 22, 1987, Antonieta filed an amended complaint against Buenaventura, Cynthia, Federico Jr., Doroteo and Tomas for accounting, partition of co-owned businesses and real properties, delivery of her 8% share, and damages.
- Respondents denied a 1946 partnership with Antonieta, limited her share to businesses in the Acknowledgement, and defended their ownership of real properties under Torrens titles.
- Compromise Agreement and RTC Decision
- During trial, Federico Jr. entered a compromise agreeing he was entitled to a 6% share alongside Antonieta and supported her claims.
- On December 18, 1992, RTC Branch 98, Quezon City, approved the compromise and rendered judgment granting Antonieta her 8% share in specified properties and corporations, moral damages, attorney’s fees and costs; Federico Jr.’s 6% share was not expressly ordered.
- Court of Appeals and Supreme Court Proceedings
- Both parties appealed. On July 30, 2002, the CA set aside the RTC decision, ordered distribution of 8% (Antonieta) and 6% (Federico Jr.) shares only in the three businesses listed in the 1957 Acknowledgement, recognized Antonieta’s stockholdings, and absolved parties from costs.
- The CA denied partial reconsideration (March 21, 2003). Antonieta’s separate petition was dismissed for procedural lapse.
- Federico Jr. filed a Rule 45 petition with the Supreme Court, contending he was entitled to a 6% share in all real properties acquired with common funds.
Issues:
- Whether the alleged unregistered partnership and the 1957 Acknowledgement funded the acquisition of the subject real properties, entitling petitioner to a 6% share.
- Whether petitioner can mount a collateral attack on Torrens-titled properties based on his claimed partnership contributions.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)