Case Digest (G.R. No. 96740)
Facts:
This case revolves around the petitioners, Virginia P. Sarmiento and Apolonia P. Catibayan, who filed a complaint for partition of a parcel of land (Lot No. 926 of the Naic Estate, G.L.R.O., Record No. 8340) located in Naic, Cavite. The property, with an area of 1,779 square meters, was covered by Transfer Certificate of Title No. 21877, which was issued on September 1, 1941, to co-owners Francisco Arguelles and Petrona Reyes. The petitioners are sisters and grandchildren of Francisco Arguelles through their mother, Leogarda Arguelles. Leogarda was the daughter of Francisco, who passed away on February 18, 1949, and Emilia Pineli, who died later on May 2, 1950. The private respondent, Simon Arguelles, is a half-brother of Leogarda, sharing the same father (Francisco Arguelles) but having a different mother (Petrona Reyes). The core of the dispute lies in the claims of the petitioners that they, along with Simon Arguelles, are legitimate co-owners of the property due to their st
Case Digest (G.R. No. 96740)
Facts:
Parties Involved:
- Petitioners: Virginia P. Sarmiento and Apolonia P. Catibayan (granddaughters of Francisco Arguelles).
- Respondents: Court of Appeals and Simon Arguelles (half-brother of Leogarda Arguelles, the petitioners' mother).
Subject Property:
- Lot No. 926 of the Naic Estate, Naic, Cavite, with an area of 1,779 square meters, covered by TCT No. 21877.
Family Background:
- Francisco Arguelles and Petrona Reyes were co-owners of the property. Francisco died in 1949, and Petrona predeceased him.
- Leogarda Arguelles, the mother of the petitioners, was the daughter of Francisco Arguelles and Emilia Pineli.
- Simon Arguelles, the respondent, is the half-brother of Leogarda, sharing Francisco Arguelles as their common father.
Petitioners' Claim:
- Petitioners claimed that as granddaughters of Francisco Arguelles, they and Simon Arguelles are co-owners of the 1/2 portion of Lot No. 926, being the only heirs of Francisco Arguelles.
Respondent's Defense:
- Simon Arguelles argued that Leogarda Arguelles was an illegitimate child of Francisco Arguelles and Emilia Pineli, who were not married. Under the old Civil Code (applicable since Francisco died in 1949), illegitimate children had no successional rights.
Trial Court Decision:
- The Regional Trial Court (RTC) ruled in favor of the petitioners, ordering the partition of the property among the parties.
Court of Appeals Decision:
- The Court of Appeals reversed the RTC decision, dismissing the complaint for judicial partition.
Supreme Court Petition:
- Petitioners sought a review of the Court of Appeals' decision, raising issues regarding the presumption of marriage and legitimacy.
Issues:
- Presumption of Marriage:
- Whether a man and a woman who lived together as husband and wife are presumed to be legally married.
- Legitimacy of Leogarda Arguelles:
- Whether Leogarda Arguelles, born out of the alleged marriage between Francisco Arguelles and Emilia Pineli, is legitimate.
- Burden of Proof:
- Whether the petitioners provided sufficient evidence to prove the marriage between Francisco Arguelles and Emilia Pineli.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Conclusion:
The Supreme Court upheld the decision of the Court of Appeals, ruling that the petitioners failed to prove the marriage between Francisco Arguelles and Emilia Pineli. Consequently, Leogarda Arguelles was not a legitimate child, and the petitioners had no right to inherit the property in question.