Case Digest (G.R. No. 209435)
Facts:
In Ernesto Lorenzo, Manuel Lorenzo, Conchita Lorenzo-Bruno, Adoracion Suelen, Avelina Suelen, and heirs of Rodolfo Lorenzo (petitioners) vs. Fortunata D. Eustaquio and her children (respondents), the Supreme Court reviewed a dispute over Lot No. 2161 in Barangay Bacabac, Camiling, Tarlac, covered by Original Certificate of Title No. 27351. On June 2, 1942, spouses Gregorio Eustaquio and Regina Lorenzo executed a deed of donation propter nuptias in favor of their son Delfin and his spouse Fortunata, purportedly gifting several parcels including the subject lot. Delfin and Fortunata accepted and openly possessed the land until Delfin’s death in 1994. Meanwhile, petitioners, as heirs of other children of Gregorio and Regina, executed a Deed of Succession and Adjudication on December 31, 1993, subdividing the property into three lots for Delfin, for petitioners, and for Fausta (another heir). Petitioners then secured a duplicate copy of OCT No. 27351 upon declaration of loss. ResponCase Digest (G.R. No. 209435)
Facts:
- Title and Parties
- Spouses Gregorio Eustaquio and Regina Lorenzo owned Lot No. 2161 (7,275 sqm) in Camiling, Tarlac (OCT No. 27351).
- They had three children: Delfin, Trinidad, and Fausta.
- Donation and Possession
- June 2, 1942: Gregorio and Regina executed a private “donation propter nuptias” in favor of their son Delfin and his bride Fortunata; Delfin and Fortunata immediately occupied the lot as owners.
- July 1994: Delfin died, leaving Fortunata and their children in possession.
- Heirs’ Succession and Litigation
- December 31, 1993: Petitioners (heirs of Trinidad and Fausta) executed a Deed of Succession subdividing Lot 2161 into Lots A, B, and C and sought issuance of a second owner’s duplicate copy of OCT No. 27351.
- 2005: Respondents (heirs of Delfin) filed Complaint for Quieting of Title, Nullity of Documents, Surrender of Title, and Damages, alleging forged succession deed and valid donation.
- Lower Court Rulings
- RTC (June 8, 2009): Declared the donation void for lack of public instrument; held respondents owners by acquisitive prescription; voided the succession deed and duplicate OCT; awarded moral damages (₱10,000) and attorney’s fees (₱10,000).
- CA (Jan. 31, 2013; Sept. 4, 2013 Resolution): Dismissed petitioners’ appeal for lack of subject index; on merits, affirmed ownership by prescription; declared succession deed void; affirmed damages award.
Issues:
- Procedural
- Whether the absence of a subject index in the appellants’ brief required dismissal of the appeal.
- Substantial
- Whether Delfin and Fortunata are rightful owners of the subject land.
- Whether the Deed of Succession and Adjudication is valid.
- Whether the award of moral damages and attorney’s fees to respondents is proper.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)