Case Digest (G.R. No. 132305)
Facts:
In the case of Ida C. Labagala v. Nicolasa T. Santiago, Amanda T. Santiago and Hon. Court of Appeals (G.R. No. 132305, December 4, 2001; 422 Phil. 699), Jose T. Santiago was registered as sole owner of a parcel of land in Sta. Cruz, Manila (TCT No. 64729). Believing the registration to be fraudulent, his sisters Nicolasa and Amanda Santiago sued him in Civil Case No. 56226 (then CFI Manila, Branch VI) and, on April 20, 1981, secured recognition of their 2/3 pro indiviso share, with an order to annotate their names on the title. Jose died intestate on February 6, 1984, and left no issue. On August 5, 1987, the sisters filed Civil Case No. 87-41515 before RTC Manila, Branch 54, seeking the 1/3 share formerly registered to Jose but in the sole possession of Ida C. Labagala under TCT No. 172334, which reflected a purported sale by Jose to Labagala in March 1979. Respondents alleged the deed was forged (thumbmark instead of signature, no consideration, delayed registration) and thatCase Digest (G.R. No. 132305)
Facts:
- Original ownership and first litigation
- Jose T. Santiago was registered as sole owner of a parcel covered by TCT No. 64729 in Sta. Cruz, Manila.
- His sisters Nicolasa and Amanda sued for recovery of a 2/3 share on April 20, 1981, claiming fraud; RTC granted their claim and ordered their inclusion in the title.
- Death of Jose and subsequent suit
- Jose died intestate without issue on February 6, 1984.
- On August 5, 1987, Nicolasa and Amanda filed before RTC Manila (Civil Case No. 87-41515) to recover the remaining 1/3 share from petitioner, Ida C. Labagala. They alleged the March 1979 deed of sale in Ida’s favor was forged or simulated.
- Trial court proceedings and decision
- Petitioner claimed her true name was Ida C. Santiago, daughter of Jose and entitled by donation or succession to his 1/3. She offered her baptismal certificate and evidence of Jose’s acknowledgment in his ITR.
- RTC Branch 54 (October 17, 1990) held the deed was a valid donation or, in any case, that petitioner was Jose’s daughter. It ordered issuance of a new title in three equal shares.
- Court of Appeals reversal
- CA noted petitioner’s birth certificate showed parents Leon Labagala and Cornelia Cabrigas, and that Jose himself had denied having children.
- CA declared Nicolasa and Amanda co-owners of the disputed 1/3 share and directed cancellation and reissuance of the title accordingly.
Issues:
- May respondents impugn petitioner’s filiation as Jose’s daughter in an action for recovery of title and possession?
- Has petitioner adduced preponderant evidence to prove she is the daughter of Jose T. Santiago and thus entitled to his 1/3 share by succession, sale, or donation?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)