Case Digest (G.R. No. 166199) Core Legal Reasoning Model
Facts:
The case "Felicisima Pino vs. Court of Appeals, et al." (G.R. No. 94114, June 19, 1991) involves a dispute over a parcel of land located in Echague, Isabela, known as Lot 6-B of Subdivision Plan (LRC) Psd-68395, which measures approximately 11,095 square meters. The property was originally acquired in 1924 by spouses Juan Gaffud and Rafaela Donato. Juan died in 1936, and the original title, O.C.T. No. 4340, was issued on January 11, 1938, listing Rafaela and their two sons, Raymundo and Cicero, as co-owners. Over the years, Rafaela Donato sold off portions of the property; one portion was sold to Fortunato Pascua, which led to the subdivision of Lot 6 into Lot 6-A and Lot 6-B. The latter, containing 11,095 square meters, was sold by Rafaela Donato to Felicisima Pino on June 10, 1970, for P10,000. The sale was registered, leading to the issuance of Transfer Certificate of Title No. T-49380 in Felicisima’s name.
Cicero Gaffud died on September 30, 1980, leaving behind h
Case Digest (G.R. No. 166199) Expanded Legal Reasoning Model
Facts:
- Ownership and Registration of the Property:
- The property in question is Lot 6-B, a portion of Lot 6 of the Echague Cadastre, Isabela, with an area of 11,095 square meters.
- It was originally acquired in 1924 by Juan Gaffud and his wife Rafaela Donato.
- After Juan Gaffud's death in 1936, the property was registered on January 11, 1938, in the names of Rafaela Donato, Raymundo Gaffud, and Cicero Gaffud as co-owners under Original Certificate of Title (OCT) No. 4340.
- Transfer of Ownership:
- The property was later transferred to Rafaela Donato through a Deed of Transfer, and Transfer Certificate of Title (TCT) No. T-30407 was issued in her name.
- On February 25, 1967, Rafaela Donato sold a portion of Lot 6 (Lot 6-A) to Fortunato Pascua, resulting in the subdivision of Lot 6 into Lot 6-A and Lot 6-B. TCT No. T-32683 was issued to Rafaela Donato for Lot 6-B.
- Sale to Petitioner Felicisima Pino:
- On June 10, 1970, Rafaela Donato sold Lot 6-B to Felicisima Pino for P10,000. The sale was registered, and TCT No. T-49380 was issued in Pino's name on July 13, 1970.
- Legal Dispute:
- Cicero Gaffud (one of the original co-owners) died in 1980, and his heirs (Demetria Gaffud, Romualdo Gaffud, Adolfo Gaffud, and Raymundo Gaffud) filed a complaint on March 9, 1982, seeking to nullify the sale to Felicisima Pino and reconvey one-half of the property (5,547.5 square meters) to them.
- They alleged that Felicisima Pino was not an innocent purchaser and that the sale was fraudulent.
- Lower Court Rulings:
- The Regional Trial Court declared the sale null and void as to the shares of Cicero Gaffud and Raymundo Gaffud, ordering Pino to reconvey one-half of the property and pay P5,000 in attorney's fees.
- The Court of Appeals affirmed the decision, ruling that Pino was not an innocent purchaser and that the action was not barred by prescription.
Issues:
- Whether Felicisima Pino was an innocent purchaser for value.
- Whether the action for nullity of sale and reconveyance was barred by prescription.
- Whether the transfer of the property from the original owners to Rafaela Donato was valid.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)