Case Digest (G.R. No. 143483)
Facts:
From 1952 until her death in 1985, Amada H. Solano served as the personal domestic helper and companion of the late Elizabeth Hankins, a French national and widow. In recognition of Solano’s faithful service, Hankins executed two deeds of donation in Solano’s favor covering parcels of land under TCT Nos. 7807 (1983) and 7808 (1984). These deeds were subsequently mislaid. In 1987, the Republic filed an escheat petition in the Regional Trial Court (RTC) of Pasay City (Br. 114) upon finding no heirs of Hankins, and the RTC rendered judgment on June 27, 1989, declaring the two parcels escheated to Pasay City, canceling TCT Nos. 7807 and 7808 and issuing new titles (TCT Nos. 129551 and 129552) in Pasay City’s name. Solano claimed in January 1997 to have rediscovered the missing deeds and filed a petition for annulment of judgment with the Court of Appeals on February 3, 1997, arguing that the donated properties were not part of Hankins’s estate at death and that the escheat award wasCase Digest (G.R. No. 143483)
Facts:
- Parties and Background
- From 1952 to 1985, private respondent Amada H. Solano served as personal domestic helper and companion of the late Elizabeth Hankins, a French national widow without close relatives.
- In recognition of Solano’s faithful service, Hankins executed two deeds of donation in favor of Solano for parcels covered by TCT Nos. 7807 and 7808 (dated 1983 and 1984).
- Loss of Deeds and Escheat Proceedings
- Solano misplaced the deeds; the Republic of the Philippines filed an escheat petition over Hankins’s estate before the RTC of Pasay City (Br. 114).
- A motion to intervene by Solano and her husband Romeo was denied on 24 June 1987 for failure to show valid claim or right.
- Finding no heirs, the RTC escheated the estate to the State, cancelled TCT Nos. 7807 and 7808, and issued TCT Nos. 129551 and 129552 to the City of Pasay.
- Petition for Annulment of Judgment in the Court of Appeals
- On 28 January 1997, upon “rediscovery” of the donation deeds, Solano filed a petition for annulment of judgment in the CA, alleging lack of RTC jurisdiction over already-donated properties and misapplication of escheat in favor of Pasay City instead of the Republic.
- The Office of the Solicitor General and the Register of Deeds (public respondents) answered, asserting lack of jurisdiction and a statute-of-limitations bar.
- On 12 November 1998, the CA gave due course to the annulment petition, rejecting jurisdictional and prescription defenses as triable issues.
- On 4 May 2000, the CA denied the motion for reconsideration and set the case for trial on the merits.
Issues:
- Whether the CA gravely abused its discretion in giving due course to Solano’s petition for annulment of judgment despite jurisdictional and prescription defenses.
- Whether the five-year prescription under Sec. 4, Rule 91, of the Revised Rules of Court barred Solano’s claim to the escheated properties.
- Whether the prior deeds of donation removed the parcels from Hankins’s estate, thus divesting the RTC of jurisdiction to escheat them.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)