Case Digest (G.R. No. L-10408)
Facts:
- The case involves Severina Marabilles and her child as plaintiffs against Alejandro Quito and Aida Quito as defendants.
- The action was filed in the Court of First Instance of Camarines Sur for the recovery of an 18-hectare land parcel in Pili, Camarines Sur.
- Defendants did not respond to the complaint but filed a motion to dismiss on three grounds:
- Plaintiffs lacked legal capacity to sue.
- The complaint failed to state a cause of action.
- The action had prescribed.
- The defendants supported their motion with two documents:
- Annex A: Transfer Certificate of Title No. 1065 issued to Guadalupe Saralde on March 31, 1941.
- Annex B: Original Certificate of Title No. 1018 issued to Patricio Marabiles on February 19, 1954, a homestead patent under Act No. 2874.
- The plaintiffs opposed the motion, but the court dismissed the complaint on November 8, 1954, with costs against the plaintiffs.
- The plaintiffs appealed to the Court of Appeals, which certified the case to the Supreme Court due to legal questions involved.
- A key issue was the plaintiffs' legal capacity to sue, given the title was in the name of deceased Patricio Marabiles without a judicial declaration of heirship.
- The lower court also found the complaint did not state a cause of action and that the action had prescribed since it was filed in 1954, long after the title transfer in 1941.
Issue:
- (Unlock)
Ruling:
- The Supreme Court ruled that the plaintiffs had the legal capacity to sue.
- The Court held that the complaint did state a cause of action against the defendants....(Unlock)
Ratio:
- The Supreme Court determined that the plaintiffs had the legal capacity to sue as heirs of Patricio Marabiles, despite the absence of a judicial declaration of heirship.
- The Court emphasized that property of a deceased individual automatically belongs to the heirs upon death, allowing them to assert rights without prior judicial declaration, supported by established jurisprudence.
- Regarding the complaint's sufficiency, the Court noted that the facts alleged were adequate to establish a cause of action, indicating that Guadalupe Saralde was the wife of Alejandro Quito, making him and their daug...continue reading
Case Digest (G.R. No. L-10408)
Facts:
The case involves Severina Marabilles and her child as plaintiffs and Alejandro Quito and Aida Quito as defendants. The action was initiated in the Court of First Instance of Camarines Sur for the recovery of an 18-hectare parcel of land located in Pili, Camarines Sur. The defendants did not respond to the complaint but instead filed a motion to dismiss on three grounds: (1) the plaintiffs lacked legal capacity to sue, (2) the complaint failed to state a cause of action, and (3) the action had prescribed. The defendants supported their motion with two documents: Annex A, which was Transfer Certificate of Title No. 1065 issued to Guadalupe Saralde on March 31, 1941, and Annex B, Original Certificate of Title No. 1018 issued to Patricio Marabiles on February 19, 1954. The latter was a homestead patent granted under Act No. 2874. The plaintiffs opposed the motion, but the court issued an order on November 8, 1954, granting the motion and dismissing the complaint with costs against the plaintiffs. The plaintiffs appealed to the Court of Appeals, which certified the case to the Supreme Court due to the purely legal questions involved. One of the key issues was whether the plaintiffs had the legal capacity to sue, given that the title was in the name of the deceased Patricio Marabiles, and there was no judicial declaration of heirship. The lower court also concluded that the complaint did not state a cause of action because it did not allege that Alejandro Quito and Aida Quito were declared heirs or administrators of the estate of Guadalupe Saralde. Lastly, the court found that the action had prescribed, ...