Case Digest (G.R. No. 150416) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Seventh Day Adventist Conference Church of Southern Philippines, Inc. (represented by Manasseh C. Arranguez et al.) versus Northeastern Mindanao Mission of Seventh Day Adventist, Inc. (represented by Josue A. Layon et al.), the dispute centers on a 1,069-sq. m. parcel in Bayugan, Agusan del Sur covered by TCT No. 4468. On April 21, 1959, spouses Felix Cosio and Felisa Cuysona executed a deed of donation in favor of the then-unincorporated South Philippine Union Mission of Seventh Day Adventist Church of Bayugan, covering 900 sq. m. for church purposes only. Alleged acceptance by an elder of the local church did not involve any juridical entity. On February 28, 1980, the same spouses sold the entire lot to Seventh Day Adventist Church of Northeastern Mindanao Mission (SDA-NEMM) for ₱2,000, and TCT No. 4468 was issued in its name. Claiming succession to the 1959 donee, petitioners filed CIVIL CASE NO. 63 in the RTC of Bayugan on September 28, 1987, seeking cancellation of respo Case Digest (G.R. No. 150416) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Subject Matter
- Petitioners are the Seventh Day Adventist Conference Church of Southern Philippines, Inc., represented by its officers, claiming succession to an alleged donation of a 1,069-sqm lot in Bayugan, Agusan del Sur.
- Respondents are the Seventh Day Adventist Church of Northeastern Mindanao Mission (SDA-NEMM), a corporation managing church properties, holding Transfer Certificate of Title (TCT) No. 4468 for the same lot.
- Donation of 1959
- On April 21, 1959, spouses Felix Cosio and Felisa Cuysona executed a deed of donation conveying to "South Philippine Union Mission of Seventh Day Adventist Church of Bayugan, Esperanza, Agusan" Lot No. 822-PLS-225, 30m by 30m (900 sqm), homestead application No. V-36704, Title No. P-285, for church-site purposes.
- The deed was allegedly accepted by Liberato Rayos, an elder, on behalf of the donee, despite the local church not yet being incorporated or having juridical personality.
- Sale of 1980 and Title Issuance
- On February 28, 1980, the Cosios sold the entire 1,069 sqm parcel (Lot No. 822-PLS-225) to SDA-NEMM for ₱2,000, payable in two installments, via public deed of sale.
- TCT No. 4468 was thereafter issued in the name of SDA-NEMM, reflecting constructive delivery and transfer of ownership pursuant to law.
- Proceedings Below
- On September 28, 1987, petitioners filed Civil Case No. 63 in the RTC of Bayugan, Agusan del Sur, seeking cancellation of respondents’ title, quieting of ownership, declaratory relief, reconveyance, injunction, and damages, based on the alleged valid 1959 donation.
- The RTC, by decision of November 20, 1992, upheld the 1980 sale, dismissed petitioners’ claims, ordered return of the property, and awarded respondents moral damages, attorney’s fees, litigation expenses, and costs.
- On appeal, the Court of Appeals affirmed with modification, deleting awards of moral damages and attorney’s fees. Petitioners’ motion for reconsideration was denied.
Issues:
- Whether the 1959 donation to the unincorporated local church vested ownership in petitioners as successors-in-interest.
- Whether the 1980 sale to SDA-NEMM effected valid transfer of ownership, thereby upholding the title in respondents’ name.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)