Title
Lorenzana vs. Lelina
Case
G.R. No. 187850
Decision Date
Aug 17, 2016
Ambrosia sold half of her land to her son Rodolfo in 1975. Anita claimed ownership via foreclosure of Aquilino's debt, but courts ruled the land was Ambrosia's paraphernal property, invalidating Anita's claim. Rodolfo's ownership upheld, Anita's documents cancelled.

Case Digest (G.R. No. 187850)
Expanded Legal Reasoning Model

Facts:

  • Procedural Background
    • The case is a petition for review on certiorari under Rule 45 of the Revised Rules of Court.
    • The petitioner, Anita U. Lorenzana, challenged a Court of Appeals (CA) Decision dated April 30, 2008 and a subsequent Resolution dated April 27, 2009 arising from an RTC decision rendered on March 7, 2005.
    • The RTC Decision had upheld respondent Rodolfo Lelina’s ownership over one-half of a 16,047-square meter piece of land and cancelled the Deed of Final Conveyance and Tax Declaration in the petitioner’s name.
  • Facts of the Land Transactions and Ownership Claims
    • On April 1, 1975, Ambrosia Lelina, wife of Aquilino Lelina, executed a Deed of Absolute Sale transferring one-half of an undivided parcel of land (covered by Tax Declaration [TD] No. 14324-C) to her son, the respondent.
      • The deed specified an area of only 810 square meters as the half of the property.
      • The deed also contained a description of the land’s boundaries: North by Constancio Batac–National Highway, East by Cecilio Lorenzana, South by Creek, and West by Andres Cuaresma.
    • Following the execution of the Deed of Absolute Sale, the respondent took possession of the property.
      • Tenants—Fidel Labiano, Venancio Lagria, and Magdalena Lopez—continued to deliver produce from both the property claimed by the respondent and the remaining half of the land until December 1995.
    • In August 1996, both the respondent and his three tenants were informed at a Municipal Agrarian Office conference that the petitioner had acquired the land by virtue of a Deed of Final Conveyance and Tax Declaration (TD No. 11-21367-A) in her name.
    • Respondent, alarmed by possible interference in his ownership and possession, filed a complaint for quieting of title and cancellation of documents on September 24, 1996, with the RTC in Tagudin, Ilocos Sur.
  • Petitioner’s Counterclaims and Evidence
    • In her Answer, petitioner claimed that she acquired the subject land, with an area of 16,047 square meters, through a foreclosure sale.
      • She argued that she became the judgment creditor in a collection case against Aquilino, with a final judgment entered on April 10, 1975.
      • Following her successful collection case, the sheriff levied on an entire land parcel (16,047 sq. m.) covered by TD No. 11-05370-A, which was then auctioned.
    • On September 29, 1977, an auction sale was conducted wherein she emerged as the sole and highest bidder.
      • A Certificate of Sale was issued and later registered with the Register of Deeds on October 18, 1977.
      • Following the lapse of the redemption period, a Deed of Final Conveyance was issued on October 9, 1978 and subsequently registered on October 16, 1978.
    • During trial, it was uncontested that the property in dispute was part of the levied property.
  • Testimonies and Subsequent Pleadings
    • Petitioner testified that she did not immediately possess the property post-auction but only took possession in 1995.
    • Respondent testified that even prior to the sale executed by his mother, another individual, Godofredo Lorenzana, owned the other half of the levied property.
      • He further claimed that there was an agreement that he would hold in trust the produce from Godofredo’s share.
    • The respondent further clarified his claim in a Memorandum dated December 16, 2004, asserting his ownership over the half of the land as originally described in the Deed of Absolute Sale.
    • The RTC ruling upheld the respondent’s ownership over the half of the levied property:
      • It declared that the levied property was exclusively owned by Ambrosia (the original owner).
      • The decision invalidated the Deed of Final Conveyance and cancelled the associated Tax Declaration (TD No. 11-21367-A).
      • The court ordered that the remaining half of the property be held in trust by respondent for Godofredo Lorenzana.
  • Appellate and Supreme Court Proceedings
    • Petitioner filed a notice of appeal, arguing that the trial court erred by:
      • Awarding the respondent one-half of the levied property, exceeding the 810 sq. m. claimed.
      • Ruling the Deed of Final Conveyance in her favor was invalid.
      • Awarding litigation expenses and attorney’s fees to the respondent.
    • The CA affirmed the RTC’s decision:
      • Ruled that the court's power in executing its judgment is limited to properties unquestionably belonging to the judgment debtor.
      • Held that the sheriff’s execution sale on Ambrosia’s solely owned property was void.
      • Deleted the award for litigation expenses and attorneys’ fees because no factual basis warranted it.
    • Ultimately, the Supreme Court denied the petition for review and affirmed the lower courts’ findings and decisions.

Issues:

  • Ownership of the Property
    • Whether respondent, by deed and uninterrupted possession, is the rightful owner of one-half (1/2) of the levied property, which is part of a 16,047 sq. m. land parcel.
    • Whether the proof of ownership derived from the Deed of Absolute Sale, despite specifying only 810 sq. m., validly extends to an area defined by its boundaries.
  • Validity of the Deed of Final Conveyance and Associated Tax Declaration
    • Whether the cancellation of the Deed of Final Conveyance and TD No. 11-21367-A in petitioner’s name was proper and legally justified.
    • Whether the sheriff’s levy, conducted on property solely belonging to Ambrosia, improperly included the property claimed by the respondent.
  • Procedural and Evidentiary Issues
    • Whether petitioner’s late objection to the admissibility of a photocopy of the Deed of Absolute Sale under the Best Evidence Rule constituted a waiver of objection.
    • Whether the execution sale, being void for involving property not solely belonging to the judgment debtor, affects the petitioner’s claim of ownership.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)
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