Case Digest (G.R. No. 169568) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Rolando Robles, represented by Atty. Clara C. Espiritu, vs. Fernando Fidel Yapcinco, et al. (G.R. No. 169568, October 22, 2014), the disputed property was originally registered under Transfer Certificate of Title (TCT) No. 20458 in the name of Fernando F. Yapcinco. On May 4, 1944, Yapcinco mortgaged the land to secure an obligation to Jose C. Marcelo, whose rights were later assigned to Apolinario Cruz. After Yapcinco’s default, the Court of First Instance of Tarlac rendered a decision on July 27, 1956 ordering judicial foreclosure: if the debt remained unpaid within ninety days, the Provincial Sheriff would sell the property at public auction. Cruz became the highest bidder on March 18, 1959, and obtained a certificate of absolute sale, but he did not register it nor obtain a judicial confirmation of sale. In 1972, Cruz donated the land to his grandchildren, including the petitioner Rolando Robles. In 1991 Apolinario Bernabe—one of the donees—falsified a deed of sale to make Case Digest (G.R. No. 169568) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Origin and Mortgage of the Property
- The parcel was originally covered by Transfer Certificate of Title (TCT) No. 20458 in the name of Fernando F. Yapcinco, married to Maxima Alcedo.
- On May 4, 1944, Yapcinco mortgaged the property to Jose C. Marcelo, who assigned his rights to Apolinario Cruz on October 24, 1944.
- Judicial Foreclosure and Auction
- Upon default, the Court of First Instance of Tarlac rendered judgment on July 27, 1956 ordering payment of ₱6,000 plus 8% interest or, after 90 days, sale at public auction.
- The auction was held on March 18, 1959. Cruz was the highest bidder; a certificate of absolute sale issued but was not registered, nor was there judicial confirmation.
- Post-Auction Transfers and Title Anomalies
- On September 5, 1972, Cruz donated the property to his grandchildren, including petitioner Rolando Robles.
- On August 29–28, 1991, Apolinario Bernabe falsified an absolute sale from Yapcinco and caused TCT No. 243719 to be issued in favor of himself and co-vendees; the mortgage release was also annotated on February 11, 1992.
- Litigations Prior to the Supreme Court
- In 2000 respondents (Yapcinco heirs) filed for nullification of TCT No. 243719; in 2001 the RTC declared that title null and void and restored TCT No. 20458.
- On December 17, 2002, petitioner sued for cancellation of title (Civil Case No. 9436); on July 7, 2003, the RTC declared the land owned by Cruz’s estate and ordered cancellation of the respondents’ title.
- The Court of Appeals, on February 24, 2005 (denied on September 12, 2005), reversed the RTC, holding that non-registration of the auction sale prevented vesting of title in Cruz and his donees.
Issues:
- Whether Apolinario Cruz, as purchaser in judicial foreclosure, acquired title despite his omission to register the certificate of sale.
- Whether the respondents, as successors-in-interest of the mortgagor, were bound by and had knowledge of the foreclosure proceedings and sale.
- Whether the respondents’ claimed rights are barred by laches.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)