Case Digest (G.R. No. 205428)
Facts:
In Mendoza v. Delos Santos (G.R. No. 176422, March 20, 2013), petitioners Maria Mendoza, in her own capacity and as attorney-in-fact for her siblings and cousins, sought recovery by reserva troncal of three parcels of land in Sta. Maria, Bulacan (Lot 1681-B, Lot 1684, and Lot 1646-B). These properties were registered in the name of respondent Julia Policarpio Delos Santos (later substituted by her heirs) but allegedly originated from the estate of Placido and Dominga Mendoza. Petitioners, as grandchildren of Placido and Dominga through their sons Antonio and Valentin, claimed that upon the intestate deaths of Exequiel Mendoza (to whom the lands were orally partitioned and adjudicated), his daughter Gregoria acquired them by inheritance and died in 1992 without issue; thereafter Julia, as Gregoria’s aunt, wrongfully adjudicated them to herself. The Regional Trial Court of Malolos ruled in favor of petitioners, ordering reconveyance and cancellation of the titles in Julia’s name.Case Digest (G.R. No. 205428)
Facts:
- Subject Properties
- Lot 1681-B – 7,749 sqm; covered by TCT No. T-149035(M) (formerly TCT No. T-101248[M]).
- Lot 1684 – 5,667 sqm; covered by TCT No. T-183631(M) (formerly TCT No. T-139184[M]).
- Lot 1646-B – 880 sqm; covered by TCT No. T-149033(M) (formerly TCT No. T-124852[M]); co-owned by Victoria Pantaleon (purchased half from petitioners).
- Parties and Family Relations
- Petitioners – Grandchildren of Placido and Dominga Mendoza:
- Children of Antonio Mendoza: Maria, Deogracias, Dionisia, Adoracion, Marcela, Ricardo.
- Children of Valentin Mendoza: Juliana, Fely, Mercedes, Elvira, Fortunato.
- Respondents – Julia Policarpio Delos Santos (substituted by her heirs: Carmen, Rosa, Zenaida Vda. de Mateo, Leonila, Elvira Vda. de Jose, Teresita-Cabuhat, Mercedita, Lydia Vda. de Hilario, Perfecto Jr., Cecilia).
- Chain of Title and Claims
- Petitioners’ Claim:
- Properties were originally owned by Placido and Dominga; orally partitioned and adjudicated to their son Exequiel.
- Upon Exequiel’s death, properties passed to his wife Leonor and daughter Gregoria; Gregoria died intestate, without issue, in 1992.
- Julia (Leonor’s sister) adjudicated the lands to herself as sole surviving heir of Leonor and Gregoria.
- Respondent’s Defense:
- Properties were purchased by Exequiel and Antonio from Alfonso Ramos in 1931.
- Only Exequiel possessed the parcels thereafter; no indication they derived from Placido and Dominga.
- Procedural History
- RTC Decision (Nov. 4, 2002) – Held for petitioners: ordered reconveyance of three parcels to petitioners, cancellation of TCTs in respondent’s name.
- CA Decision (Nov. 16, 2006) – Reversed and set aside RTC; dismissed petitioners’ complaint.
- CA Resolution (Jan. 17, 2007) – Denied petitioners’ motion for reconsideration.
- SC Petition – Petitioners raise two questions of law:
- Whether the properties are reservable under Article 891, Civil Code (reserva troncal).
- Whether petitioners have a right to claim reservation.
Issues:
- Are the subject properties “reservable” under Article 891 of the Civil Code?
- Are petitioners entitled to invoke reserva troncal and recover the properties?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)