Title
Quijada vs. Court of Appeals
Case
G.R. No. 126444
Decision Date
Dec 4, 1998
Heirs of Trinidad Quijada contested land sales after donation reverted; SC upheld validity, citing inchoate interest, no laches, and no bad faith.
A

Case Digest (G.R. No. 126444)

Facts:

  • Parties and Property
    • Petitioners are the seven children and heirs of the late Trinidad Quijada.
    • Respondents are Regalado Mondejar and those who acquired land portions from him, and the Court of Appeals.
  • Background and Transactions
    • Trinidad inherited a two-hectare parcel in San Agustin, Talacogon, Agusan del Sur, from her father, Pedro Corvera.
    • On April 5, 1956, Trinidad and her siblings executed a conditional deed of donation of the parcel to the Municipality of Talacogon for a proposed provincial high school, with an automatic reversion clause if the school were discontinued or never built.
    • Despite the donation, Trinidad remained in possession and on July 29, 1962 sold one hectare to Mondejar by written deed, then verbally sold the remaining hectare to him evidenced only by receipts.
    • In 1980 petitioners filed an ejectment suit against Mondejar, dismissed for failure to prosecute.
    • In 1987, the Sangguniang Bayan of Talacogon passed a resolution reverting the donated land to the donor when the school project failed to materialize.
    • Prior to petitioners’ 1988 quieting-of-title action, Mondejar had sold land portions to private respondents Fernando Bautista, Rodolfo Goloran, Efren Guden and Ernesto Goloran.
  • Judicial Proceedings
    • 1988 – Petitioners filed for quieting of title, recovery of possession, cancellation of deeds, attorney’s fees and damages, alleging Trinidad had no right to sell while ownership was with the municipality.
    • Defendants claimed valid sale, good-faith purchase, and raised laches/prescription.
    • 1993 – RTC rendered judgment for petitioners: ordered cancellation of deeds, restoration of possession, removal of improvements, and awarded P48,000 for fees, expenses and moral damages.
    • 1996 – CA reversed: declared respondents rightful owners and possessors, with no pronouncement as to costs.
    • CA denied petitioners’ motion for reconsideration; petitioners elevated case to the Supreme Court.

Issues:

  • Whether the sales by Trinidad Quijada to Mondejar were valid in view of the prior conditional donation and reversion clause.
  • Whether petitioners’ action is barred by laches.
  • Whether the trial court erred in awarding attorney’s fees, litigation expenses and moral damages.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

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