Case Digest (G.R. No. 117228) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Morales v. Court of Appeals, spouses Ranulfo Ortiz, Jr. and Erlinda Ortiz (private respondents) filed on February 2, 1987 in the Regional Trial Court (RTC) of Calbayog City Civil Case No. 265 an action for recovery of possession, damages and a writ of preliminary mandatory injunction against Rodolfo Morales. They claimed absolute ownership over a two‐storey house and lot at the corner of Umbria Street and Rosales Boulevard, Brgy. Central, Calbayog City, on the strength of a public Deed of Absolute Sale executed by their predecessor‐in‐interest, Judge Celso Avelino. On March 4, 1988, Priscila Morales successfully moved to intervene. After Rodolfo’s death on November 30, 1988, his heirs were substituted. On August 26, 1991, the RTC declared the Ortizes rightful owners, permanently enjoined defunct Rodolfo Morales and his heirs to vacate and demolish a beauty shop he had constructed without consent, and awarded monthly rentals, moral damages, litigation expenses and attorney’s f Case Digest (G.R. No. 117228) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Procedural History
- In February 1987, spouses Ranulfo and Erlinda Ortiz filed Civil Case No. 265 in the RTC of Calbayog City for recovery of possession of a parcel of land with improvements, moral damages, litigation expenses, attorney’s fees, and a permanent mandatory injunction against Rodolfo Morales.
- On 2 February 1988, Priscila Morales moved to intervene; no opposition was filed, and intervention was granted on 4 March 1988. Rodolfo Morales died on 30 November 1988; on 9 February 1989 the court allowed his substitution by his heirs Roda, Rosalia, Cesar, and Priscila Morales. Trial on the merits concluded on 16 November 1990.
- On 26 August 1991, the RTC rendered judgment declaring the Ortiz spouses absolute owners, ordering the Morales intervenors to vacate, remove a beauty shop, pay monthly rent (₱1,500 from March 1987), moral damages (₱75,000), litigation expenses (₱5,000), attorney’s fees (₱10,000), and costs; it made permanent the preliminary injunction. The CA (Seventeenth Division) affirmed in toto on 20 April 1994. Petitioners then brought a Rule 45 petition to the Supreme Court.
- Material Facts
- Celso Avelino, bachelor and City Fiscal of Calbayog, purchased two adjoining parcels at corner Umbria St. and Rosales Blvd., Brgy. Central, Calbayog City, on 8 July 1948 from Alejandra Mendiola and Celita Bartolome by public Deed of Sale; he consolidated tax declarations, caused a survey (Lot 1949), built a two-storey concrete residence, and paid realty taxes over decades.
- Without his knowledge, defendant Rodolfo Morales constructed a small beauty shop on the lot. In 1987 Celso sold the property by Deed of Absolute Sale (Exh. aCa) to the Ortiz spouses; Morales refused to vacate or demolish his beauty shop unless paid ₱35,000 (though valued under ₱5,000).
- Plaintiffs demanded vacation orally and in writing (Exhs. aLa, aMa); Morales refused. As plaintiffs prepared urgent repairs on the dilapidated house, Morales lodged boarders, claimed ownership, and resisted their entry. Plaintiffs filed Civil Case No. 265.
- The RTC found plaintiffs’ documentary evidence (conveyance deeds, tax declarations, surveys, tax receipts) clear and credible. Intervenor’s claim rested on self-serving, evasive testimony; co-heirs never contested Celso’s title; they failed to partition; Morales and Priscila showed laches; the condition of the building belied intervenor’s ownership pretensions.
Issues:
- Did an implied resulting trust arise under Art. 1448 of the Civil Code, making Celso Avelino trustee for his parents and siblings?
- Was Rodolfo Morales a builder in good faith entitled to indemnity under Arts. 448 and 453 of the Civil Code?
- Are the Ortiz spouses entitled to moral damages, attorney’s fees, and litigation expenses?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)