Case Digest (G.R. No. 204029) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In G.R. No. 204029 decided on June 4, 2014, petitioners Avelina Abarientos Rebusquillo (substituted by her heirs, except Emelinda R. Gualvez) and Salvador A. Orosco sought to annul and revoke an Affidavit of Self-Adjudication dated December 4, 2001 and a Deed of Absolute Sale dated February 6, 2002 executed in favor of respondents spouses Domingo and Emelinda Rebusquillo Gualvez. The subject property was an untitled 2,869-square-meter parcel in Legazpi City covered by Tax Declaration ARP No. 0141. Eulalio Abarientos died intestate on July 3, 1964, survived by his wife, Victoria Villareal (who died intestate June 30, 1983), six legitimate children (including Avelina and Fortunata, mother of Salvador) and one illegitimate child. Petitioners allege that in 2001 respondents induced Avelina to sign documents under the pretext of facilitating titling, but these turned out to be an affidavit and a deed conveying the entire property. When respondents ignored Avelina’s protest, she filed Case Digest (G.R. No. 204029) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Background
- Petitioners Avelina Abarientos Rebusquillo (substituted by her heirs, except Emelinda R. Gualvez) and Salvador A. Orosco filed a Complaint in RTC Branch 4, Legazpi City on October 26, 2004 for annulment and revocation of:
- An Affidavit of Self-Adjudication dated December 4, 2001
- A Deed of Absolute Sale dated February 6, 2002
- Respondents Spouses Domingo and Emelinda Rebusquillo Gualvez were the grantees of both documents.
- Decedent’s Estate
- Eulalio Abarientos died intestate on July 3, 1964, leaving untitled land in Legazpi City (2,869 sqm; Tax Decl. ARP 0141).
- Survived by his wife Victoria Villareal (d. 1983), six legitimate children (including Avelina and Fortunata, mother of Salvador), and one illegitimate child.
- Execution and Discovery
- In 2001, Avelina, at the behest of respondents, signed documents allegedly to facilitate titling.
- In 2003, petitioners discovered the Affidavit and Deed actually conveyed the property to respondents.
- Respondents admitted those documents were intended to enable titling, with an agreement that all heirs would share proceeds and reimburse costs.
- Proceedings Below
- RTC Decision (Jan. 20, 2009): Annulled both documents for lack of sole‐heir status and real intent to sell; ordered cancellation of Tax Decl. ARP 4143, reinstatement of ARP 0141; ordered petitioners to refund ₱50,000.
- CA Decision (Mar. 30, 2012) and Resolution (Sept. 25, 2012): Reversed RTC, holding heirship issues require special intestate proceedings and notarized deed enjoys presumption of regularity.
- Petitioners elevated the case to the Supreme Court via Rule 45 Petition for Review on Certiorari.
Issues:
- Can heirship and the validity of extrajudicial settlement documents be determined in an ordinary civil action?
- Was the Affidavit of Self-Adjudication valid when Avelina was not the sole heir?
- Was the Deed of Absolute Sale void for lack of true intent and as an absolutely simulated contract?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)