Case Digest (G.R. No. 124605) Core Legal Reasoning Model
Facts:
In the case of Enriquito Serna and Amparo Rasca v. Court of Appeals, Santiago Fontanilla, and Rafaela Rasing (G.R. No. 124605, June 18, 1999), the controversy revolves around the ownership of a parcel of land in Barangay Lucap, Alaminos, Pangasinan, covering an area of 12,508 square meters. The land originally belonged to Dionisio Fontanilla, who was declared its owner for taxation in 1921. Dionisio had four children: Rosa, Antonio, Jose, and Lorenza. The respondents, Santiago Fontanilla and his wife Rafaela Rasing, are descendants of Jose, while Amparo Rasca (now married to Enriquito Serna) is Lorenza's daughter. Rosa sold the land to her nephew Santiago in 1955, evidenced by a notarized but unregistered deed. Respondents built a house on the land in 1955 and paid taxes continuously thereafter. Meanwhile, petitioners Enriquito and Amparo Serna, taking advantage of respondents’ absence abroad (1978–1981), applied for registration of the land under their names, resulting in
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Case Digest (G.R. No. 124605) Expanded Legal Reasoning Model
Facts:
- Parties and Family Relationship
- Dionisio Fontanilla had four children: Rosa, Antonio, Jose, and Lorenza.
- Rosa married Estanislao Pajaro and had two children: Fructoso and Paciencia.
- Lorenza married Alberto Rasca and had a daughter, Amparo Rasca (petitioner), married to Enriquito Serna.
- Jose had a son, Santiago Fontanilla (respondent), married to Rafaela Rasing.
- The parties involved are therefore first cousins.
- Ownership and Possession of Land
- Dionisio Fontanilla was original owner and possessor of a 12,508 sq. m. parcel in Barangay Lucap, Alaminos, Pangasinan.
- The land was declared under Dionisio’s name for tax purposes in 1921, surveyed the same year with approval by Bureau of Lands in 1923.
- Due to unpaid survey costs, Dionisio sold the land in 1938 to his daughter Rosa Fontanilla.
- Rosa paid real estate taxes starting 1939 and sold the property to Santiago Fontanilla in 1955 by notarized deed of absolute sale (not registered).
- Respondents built their house on the land between 1955-1957.
- Rosa’s heirs executed another deed of absolute sale over the same land in favor of Santiago in 1957.
- Petitioners’ Action and Registration of Title
- In 1978, while respondents stayed abroad, petitioners Enriquito and Amparo Serna applied for registration of the land in their name before the land registration court.
- In 1979, the court approved and issued Original Certificate of Title (OCT) No. 139 to petitioners, transcribed in January 1980.
- Litigation and Claims
- Respondents filed action for reconveyance with damages and sought annulment of OCT No. 139 in 1981.
- Petitioners admitted Dionisio was original owner but claimed they bought the land in 1978 for P3,000 from Lorenza Fontanilla-Rasca, who traced title from her husband Alberto Rasca.
- Petitioners claimed Turner Land Surveying Co. took the property as payment for unpaid survey services and was redeemed by Alberto Rasca (deed not produced).
- Trial court in 1992 ruled in favor of respondents declaring them absolute owners, ordering return of OCT, attorney’s fees, exemplary damages, and costs.
- Both parties appealed to the Court of Appeals; respondents questioned lack of moral damages, petitioners disputed trial court’s findings.
- The Court of Appeals affirmed the trial court decision in 1995 and denied petitioners’ motion for reconsideration in 1996.
- Issues Raised in Petition for Review
- Whether the appealed decision is supported by evidence.
- Whether the decision accords with law and jurisprudence.
Issues:
- Is the decision of the Court of Appeals factually supported, particularly on ownership and possession of the land?
- Does the appealed decision conform to existing laws and relevant jurisprudence on land registration, prescription, and fraud?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)