Case Digest (G.R. No. 231721-22)
Facts:
- The case concerns a 19-hectare unregistered parcel of land, Lot No. 1089, in Taba, La Paz, Carmen, Davao.
- Originally owned by Candido Bustamante and Candida Dela Cruz-Bustamante (Spouses Bustamante).
- Inherited by their son, Eugenio Bustamante, who married Juana Bustamante.
- Eugenio and Juana had five children: Victoria, Gregoria, Salome, Ramon, and Adelaida (collectively, the Bustamantes).
- After Eugenio's death, Juana and the Bustamantes partitioned Lot No. 1089 through a Deed of Extrajudicial Partition (DEP) on November 15, 1977, dividing it into six equal portions.
- A survey on December 7, 1979, resulted in an approved subdivision plan that mistakenly interchanged Juana and Gregoria's shares.
- Despite the error, Juana and Gregoria possessed their shares as per the DEP.
- Upon Gregoria's death, her share was inherited by her eight children (collectively, Gregoria Heirs).
- Juana, who later cohabitated with Arturo Remillano, had two children, Emelita and Felicitas (collectively, the Remillanos).
- A series of transactions, including a Deed of Exchange and a Deed of Sale, transferred portions of Lot No. 1089-F to Jesus Ulay (petitioner).
- Maranguyod Bustamante, the widow of Ramon, entered the disputed portion, prompting Jesus to file an action for recovery of possession.
- The Bustamantes filed an action for annulment of deeds, reconveyance, and damages.
- The Regional Trial Court (RTC) ruled in favor of the Bustamantes, declaring several deeds null and void and ordering the reconveyance of the property.
- The Court of Appeals (CA) affirmed the RTC's decision with modifications, leading Jesus to file a petition for review before the Supreme Court.
Issue:
- (Unlock)
Ruling:
- The Supreme Court partly granted the petition.
- The Court affirmed the CA's decision in part, holding that the DEP is a binding contract enforceable against the Bustamantes and their successors.
- The erroneous designation in the subdivision plan could have been corrected by a relocation survey.
- The Deed of Exchange was valid as it corrected the erroneous subdivision plan and carried out the intent of the parties under the DEP.
- The Deed of Sale to Jesus was null and void as it purported t...(Unlock)
Ratio:
- The DEP is a binding contract enfor...continue reading
Case Digest (G.R. No. 231721-22)
Facts:
The case involves a dispute over a 19-hectare unregistered parcel of land designated as Lot No. 1089, located in Taba, La Paz, Carmen, Davao, originally owned by Candido Bustamante and Candida Dela Cruz-Bustamante (Spouses Bustamante). The land was inherited by their son, Eugenio Bustamante, who later married Juana Bustamante. Eugenio and Juana had five children: Victoria Bustamante-Quijada, Gregoria Bustamante-Concha, Salome Bustamante-Sarol, Ramon Bustamante, and Adelaida Bustamante-Pedroroja (collectively, the Bustamantes). After Eugenio's death, Juana and the Bustamantes partitioned Lot No. 1089 through a Deed of Extrajudicial Partition (DEP) dated November 15, 1977, dividing the land into six equal portions. A survey conducted on December 7, 1979, resulted in an approved subdivision plan that inadvertently interchanged the shares of Juana and Gregoria. Despite this error, Juana and Gregoria continued to possess their respective shares as per the DEP. Upon Gregoria's death, her share was inherited by her eight children (collectively, Gregoria Heirs). Juana, who later cohabitated with Arturo Remillano, had two children, Emelita Remillano-Comendador and Felicitas Remillano-Boyles (collectively, the Remillanos). A series of transactions, including a Deed of Exchange and a Deed of Sale, led to the transfer of portions of Lot No. 1089-F to Jesus Ulay (petitioner). Maranguyod Bustamante, the widow of Ramon, entered the disputed portion, prompting Jesus to file an action for recovery of possession. The Bustamantes filed an action for annulment of deeds, reconveyance, and damages. The Regional Tri...