Case Digest (G.R. No. 146865) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Donato S. Paulmitan, et al. v. Court of Appeals, et al. (G.R. No. 61584, November 25, 1992), the decedent Agatona Sagario Paulmitan died in 1953 owning two parcels in Negros Occidental: Lot No. 757 (1,946 sq m, OCT No. RO-8376) and Lot No. 1091 (69,080 sq m, OCT No. RO-11653). She left two sons: Pascual (died later in 1953) and Donato Paulmitan (petitioner). Pascual’s seven children (Alicio, Elena, Abelino, Adelina, Anita, Baking and Anito) are respondents, while Donato’s only child is Juliana P. Fanesa (co-petitioner) together with her husband Rodolfo. From 1953 until 1963 the estate was unpartitioned and titles remained in Agatona’s name. On August 11, 1963 Donato executed an Affidavit of Declaration of Heirship, extrajudicially adjudicating Lot 757 to himself; the Register of Deeds issued TCT No. 35979 in his name on August 20, 1963. Lot 1091 had been forfeited for unpaid taxes in 1952 and sold to the Provincial Government; Juliana redeemed it on May 29, 1974 for ₱2,959.09 Case Digest (G.R. No. 146865) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Succession and Heirs
- Agatona Sagario Paulmitan died in 1953 owning two parcels in Negros Occidental:
- Lot No. 757 (1,946 sqm) under OCT No. RO-8376.
- Lot No. 1091 (69,080 sqm) under OCT No. RO-11653.
- She left two legitimate sons:
- Extrajudicial Transactions
- August 11, 1963 – Donato executed Affidavit of Declaration of Heirship, adjudicating Lot No. 757 to himself; Register of Deeds issued TCT No. 35979.
- 1952–1963 – Lot No. 1091 forfeited for non-payment of taxes; Provincial Government bought it; on May 29, 1974 Juliana redeemed it for ₱2,959.09.
- May 28, 1974 – Donato sold Lot No. 1091 to Juliana by deed of sale.
- Judicial Proceedings
- January 18, 1975 – Respondents filed complaint for partition of both lots plus damages.
- April 22, 1976 – Trial court dismissed action on Lot No. 757 (prescription).
- May 20, 1977 – Trial court ruled for respondents on Lot No. 1091: each side entitled to ½ undivided share; ordered partition; awarded fruits and redemption reimbursement.
- July 14, 1982 – Court of Appeals affirmed.
- November 25, 1992 – Supreme Court denied petition for certiorari.
Issues:
- Whether Donato’s extrajudicial heirship affidavit and TCT issuance over Lot No. 757 extinguished respondents’ rights.
- Whether Donato’s sale of Lot No. 1091 to Juliana vested her with ownership of the entire lot.
- Whether Juliana’s redemption of Lot No. 1091 from the Provincial Government gave her exclusive title to the entire lot.
- Whether respondents are entitled to fruits of Lot No. 1091 from 1966 until partition.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)