Case Digest (G.R. No. 227894) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Ocampo v. Ocampo (G.R. No. 227894, July 5, 2017), petitioner Jose S. Ocampo and respondent Ricardo S. Ocampo, Sr., full-blood brothers and sons of the late Basilio Ocampo and Juliana Sunglao, disputed co-ownership of a 150-square-meter lot with improvements at 2227 Romblon Street, Sampaloc, Manila. The property was originally registered under TCT No. 36869 in their parents’ names. In 1970, an Extra-Judicial Settlement with Waiver (“ESW”), allegedly bearing Ricardo’s forged signature, was notarized to transfer the land into TCT No. 102822 in favor of petitioner and his wife. The NBI confirmed forgery, leading Ricardo to file a complaint for partition and annulment of title on June 29, 1992; petitioner resisted, claiming donation propter nuptias, repayment of loans, waiver by respondent, a subsequent deed of sale by their father, and the one-year indefeasibility of Torrens titles. The RTC initially dismissed the complaint for prescription (Jan. 21, 1994), but the CA nullified t Case Digest (G.R. No. 227894) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Property
- Petitioner Jose S. Ocampo and respondent Ricardo S. Ocampo, Sr. are full-blooded brothers, heirs of Basilio Ocampo and Juliana Sunglao.
- The subject property is a 150-sqm lot with improvements at 2227 Romblon St., Sampaloc, Manila, originally titled under TCT No. 36869 in their parents’ names.
- Origin of Dispute
- Respondent filed for partition and annulment of petitioner’s TCT No. 102822, alleging petitioner and his wife forged respondent’s signature on a notarized Extra-Judicial Settlement with Waiver (ESW) dated September 1970, causing wrongful transfer.
- Petitioner claimed a valid donation propter nuptias, loans from DBP and SSS to build a new house, and that the ESW was properly executed, making TCT No. 102822 indefeasible after one year.
- Procedural History
- RTC dismissed the complaint for prescription in January 1994; CA nullified that dismissal and remanded for trial.
- After trial, RTC ruled in favor of respondent (Sept. 30, 2011); CA affirmed (June 28, 2016); petitioner’s motions for reconsideration were denied and he filed a Rule 45 petition before the SC.
Issues:
- Did the Court of Appeals err in concluding the ESW signature was forged based on the evidence?
- Is the ESW a void or inexistent contract such that the action to annul it is imprescriptible?
- Is the action to annul the ESW barred by prescription or by laches?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)