Case Digest (G.R. No. L-5335) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Tiburcio Samonte v. Court of Appeals, decided on July 12, 2001, petitioner Tiburcio Samonte challenged the appellate ruling in CA-G.R. CV No. 16645 that affirmed the trial court’s annulment of various Torrens titles covering a 12,753-square-meter parcel (Lot 216) in Nasipit, Agusan del Norte. Lot 216 was originally registered under Original Certificate of Title No. RO-238(555) in the names of Apolonia Abao and her daughter Irenea Tolero. After both died, their heirs (respondents Eugenia Dango Gadiano et al.) filed Civil Case No. 1816 for quieting of title, recovery of possession, annulment of subsequent certificates and reinstatement of OCT No. RO-238(555). Respondents alleged that Ignacio Atupan secured a fraudulent “Affidavit of Extra-judicial Settlement” in 1957, misrepresenting himself as sole heir of Abao, which paved the way for Transfer Certificate of Title No. RT-476 in favor of Abao’s purported purchasers, including the Jadol spouses. Subsequent subdivisions and sale Case Digest (G.R. No. L-5335) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Procedural Posture
- Petitioner Tiburcio Samonte, defendant in Civil Case No. 1816 before the Regional Trial Court (RTC) of Nasipit, Agusan del Norte, sought review by certiorari of the Court of Appeals (CA) Decision dated November 29, 1991 (CA-G.R. CV No. 16645) and its February 21, 1992 Resolution denying reconsideration.
- Respondents are the surviving heirs of Apolonia Abao and Irenea Tolero (deceased), plaintiffs in RTC Civil Cases No. 1672 and 1816, consolidated on appeal.
- Background of Lot 216 Titles
- Original Title
- Lot 216 (12,753 sqm) at Nasipit, Agusan del Norte, was registered under OCT No. RO-238 (issued 1927) in equal undivided shares to Apolonia Abao and her daughter Irenea Tolero.
- OCT No. RO-238 was administratively reconstituted on August 8, 1957 as OCT No. RO-238(555).
- Fraudulent Cancellation and Subsequent Transfers
- On August 8, 1957, by an affidavit of extrajudicial settlement and confirmation of sale executed by Ignacio Atupan—which misrepresented him as sole heir of Abao—OCT No. RO-238(555) was canceled and TCT No. RT-476 issued to Irenea Tolero (½ share) and Nicolas Jadol (½ share).
- On February 13, 1959, RTC-approved subdivision plan split Lot 216 into 216-A (TCT No. RT-553 issued to Samonte) and 216-B (TCT No. RT-554 issued to Tolero and Jadol). A further subdivision on the same date created Lot 216-B-1 (TCT No. RT-555 issued to Jacobo Tagorda) and 216-B-2 (TCT No. RT-556 issued to Tolero and Jadol).
- Trial Court Proceedings and Judgment
- Civil Case No. 1816 (Entire Lot 216)
- Respondents sought annulment of TCT Nos. RT-476, RT-553, RT-554, RT-555, RT-556, and reinstatement of OCT No. RO-238(555).
- RTC rendered judgment declaring respondents co-owners of Lot 216, reinstating OCT No. RO-238(555), canceling all subsequent titles, voiding subdivisions, ordering defendants to vacate and remove improvements, awarding P20,000.00 use and occupation, P5,000.00 attorney’s fees, and costs.
- Appeals and CA Decision
- Defendants (including Samonte) appealed both Cases Nos. 1672 and 1816; CA consolidated the appeals.
- CA affirmed the RTC judgments in toto, finding the 1957 cancellation fraudulent, respondents’ action timely under implied trust doctrine, and Samonte in bad faith.
Issues:
- Whether the CA erred in refusing to deem discovery of fraud as taking place at registration under Carantes v. Court of Appeals, thus barring respondents’ action by prescription.
- Whether petitioner Samonte qualified as a buyer in good faith for value protected by the Torrens system despite notice of fraud.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)