Case Digest (G.R. No. 175720) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Cresenciana Tubo Rodriguez (now deceased), substituted by Susana A. Llagas, v. Evangeline Rodriguez, Belen Rodriguez and Buenaventura Rodriguez (G.R. No. 175720, September 11, 2007), petitioner claimed ownership and possession of a five‐unit apartment situated on San Jose Street, Guadalupe Nuevo, Makati City, originally covered by TCT No. 144865 in the name of Juanito Rodriguez. On October 27, 1983, Juanito executed a Huling Habilin at Testamento bequeathing apartments D and E to petitioner, apartment A to his son Benjamin (deceased husband of respondent Evangeline), apartment B to respondent Buenaventura, and apartment C to respondent Belen. On June 14, 1984, Juanito sold the entire property by Deed of Absolute Sale to petitioner, resulting in the cancellation of TCT No. 144865 and issuance of TCT No. 150431 in petitioner’s name. On September 20, 2001, petitioner filed a complaint for unlawful detainer against respondents, alleging that they had wrongfully leased their respe... Case Digest (G.R. No. 175720) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Property
- Petitioner Cresenciana Tubo Rodriguez (substituted by Susana A. Llagas) v. Respondents Evangeline, Belen and Buenaventura Rodriguez.
- Subject: a five-door apartment on San Jose Street, Guadalupe Nuevo, Makati City; originally covered by TCT No. 144865.
- Deeds and Testamentary Disposition
- October 27, 1983: Juanito Rodriguez executed a “Huling Habilin at Testamento” bequeathing apartment D and E to Cresenciana, apartment A to Benjamin (deceased husband of Evangeline), apartment B to Buenaventura, and apartment C to Belen.
- June 14, 1984: Juanito sold the entire property to Cresenciana by Deed of Absolute Sale; TCT No. 144865 was cancelled and TCT No. 150431 issued in her name.
- Proceedings Below
- September 20, 2001: Petitioner filed an unlawful detainer complaint against respondents for occupying apartments A, B and D and leasing them to third parties without consent.
- Respondents’ answer: they claimed co-ownership by succession, alleged the sale was a simulated transaction induced by undue influence, and pointed to the August 23, 1990 Partition Agreement recognizing their respective shares under the will.
- February 26, 2002 (MTC): Complaint dismissed; respondents awarded P10,000 attorney’s fees and costs.
- RTC Branch 134: Reversed MTC, held petitioner’s Torrens title and deed of sale conclusive; will unprobated and partition void; ordered respondents to vacate and pay P5,000 per unit monthly.
- CA (June 27, 2006): Reinstated MTC decision, ruling that ownership issue—Huling Habilin and partition—must be resolved provisionally to determine possession; denied reconsideration.
- Petitioner elevated the case to the Supreme Court via petition for review on certiorari.
Issues:
- Whether the Court of Appeals erred in reversing the RTC’s decision and reinstating the MTC’s dismissal of petitioner’s ejectment complaint.
- Whether the CA committed grave abuse of discretion in finding that the unprobated Huling Habilin at Testamento transmitted ownership of specific apartments to respondents and petitioner.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)