Case Digest (G.R. No. 57288)
Facts:
In Leonila Sarmiento v. Hon. Enrique A. Agana et al. (G.R. No. L-57288, April 30, 1984), petitioner Leonila Sarmiento acquired by deed of sale on September 7, 1974, a 145-sq.-m. lot in Paranaque previously believed by spouses Ernesto and Rebecca Valentino to belong to the latter’s mother. In 1967, believing the lot theirs, the Valentinos constructed a residence at their expense, estimated at ₱8,000–₱10,000. On January 6, 1975, after learning that Sarmiento had purchased the property for ₱15,000, the spouses were asked to vacate, prompting Sarmiento to file an ejectment suit on April 21, 1975, before the Municipal Court of Paranaque. Respondents proved their good faith and testified that their house then cost ₱30,000–₱40,000; the trial court, however, fixed its value at ₱20,000 and ordered ejectment upon payment of that sum. On October 17, 1977, the Court of First Instance of Pasay (Branch XXVIII) modified the judgment under Article 448 of the Civil Code, giving Sarmiento the optCase Digest (G.R. No. 57288)
Facts:
- Procedural Posture
- Petitioner Leonila Sarmiento filed an ejectment suit in the Municipal Court of Parañaque against spouses Ernesto Valentino and Rebecca Lorenzo-Valentino for unlawfully occupying her land.
- The Municipal Court valued the improvements at ₱20,000 and ordered eviction upon payment; the Court of First Instance of Pasay City, on memoranda under R.A. 6031 and Article 448 of the Civil Code, modified the judgment to require Sarmiento to either indemnify respondents ₱40,000 or sell the land to them for ₱25,000.
- Construction and Sale of Property
- In 1967, believing the lot to belong to his mother-in-law, Ernesto built a residential house on a 145 sqm lot (Lot D, Paranaque) at a cost of ₱8,000–10,000.
- The lot was actually titled to Jose C. Santos Jr., who sold it to Sarmiento on September 7, 1974 for ₱15,000.
- Ejectment Proceedings and Valuations
- January 6, 1975: Sarmiento demanded respondents vacate; April 21, 1975: she filed ejectment.
- At trial, Ernesto testified the house’s value was ₱30,000–40,000 (uncontroverted); the Municipal Court set it at ₱20,000. On appeal, the CFI chose the ₱40,000 figure and set the land’s value at ₱25,000.
- Certiorari Petition
- Sarmiento sought certiorari relief in the Supreme Court, alleging the CFI abused its discretion in valuation and in the relief granted.
Issues:
- Whether respondents were builders in good faith entitled to the options under Article 448 of the Civil Code.
- Whether the Court of First Instance abused its discretion in valuing the house at ₱40,000 and the land at ₱25,000.
- Whether the relief—granting Sarmiento the choice to indemnify or sell—comported with the Civil Code.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)