Case Digest (G.R. No. 205879) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Skunac Corporation and Alfonso F. Enriquez v. Roberto S. Sylianteng and Caesar S. Sylianteng, G.R. No. 205879, decided on April 23, 2014 under the 1987 Philippine Constitution, the dispute stems from two parcels in Block 2, Pujalte Subdivision, Greenhills, San Juan City (Lot 1, 1,250 sqm; Lot 2, 990 sqm), originally covered by Mother Title No. 78865 in the name of Luis A. Pujalte since October 29, 1945. Respondents Roberto and Caesar Sylianteng claimed ownership via a June 20, 1958 Deed of Sale by Luis to their mother, Emerenciana Sylianteng (TCT No. 42369), and a June 27, 1983 Deed of Absolute Sale by Emerenciana to them (TCT No. 39488). Petitioners Skunac and Enriquez asserted title from Romeo Pujalte—declared sole heir of Luis in Special Proceedings No. 3366—who secured TCT No. 5760-R and sold the lots in 1992, resulting in TCT No. 5888-R (Skunac) and 5889-R (Enriquez). The Regional Trial Court (Pasig City, Branch 160) nullified respondents’ titles and upheld petitioners a Case Digest (G.R. No. 205879) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Subject Properties and Original Title
- Two parcels (Lot 1: 1,250 sqm; Lot 2: 990 sqm) in Pujalte Subdivision, San Juan City, originally under Mother Title TCT No. 78865 in the name of Luis Pujalte.
- Memorandum Entry No. P.E. 4023 annotated on TCT No. 78865 recording sale to Emerenciana Sylianteng on June 20, 1958 and issuance of TCT No. 42369.
- Chain of Transactions
- Emerenciana sold the lots to Roberto S. Sylianteng and Caesar S. Sylianteng by Deed of Absolute Sale dated June 27, 1983; TCT No. 39488 issued to respondents.
- Romeo Pujalte declared sole heir of Luis in Special Proceedings No. 3366; Mother Title reconstituted, TCT No. 5760-R issued in his name.
- Romeo sold Lot 1 to Skunac Corporation and Lot 2 to Alfonso F. Enriquez in 1992; issuance of TCT Nos. 5888-R and 5889-R.
- Procedural History
- RTC Pasig (Nov 16, 2007) – rendered judgment for petitioners, canceled TCT Nos. 42369 and 39488, upheld petitioners’ TCT Nos. 5888-R and 5889-R.
- CA (Aug 10, 2012) – reversed RTC, nullified petitioners’ titles, reinstated respondents’ titles, awarded P500,000 moral and exemplary damages, P250,000 attorney’s fees, costs.
- CA Resolution (Feb 18, 2013) – denied petitioners’ motion for reconsideration.
- Petition for Review – filed with Supreme Court, raising errors on application of Civil Code Article 1544, authenticity of deeds, regularity of annotations, validity of petitioners’ title, and damages.
Issues:
- Admissibility of Questions of Fact
- Whether the Supreme Court may review factual findings under Rule 45 due to conflicting RTC and CA decisions.
- Validity of Respondents’ Title
- Whether Emerenciana validly acquired the lots from Luis in 1958.
- Whether respondents validly acquired the lots from Emerenciana in 1983.
- Validity of Petitioners’ Title
- Whether petitioners validly acquired the lots from Romeo Pujalte in 1992.
- Whether Romeo had title as sole heir and authority to sell.
- Application of Legal Provisions
- Whether Civil Code Article 1544 on double sale applies.
- Whether the best evidence rule barred the admission of the duplicate deed of sale.
- Whether the annotation (P.E. 4023) and registration entries were regular.
- Damages and Attorney’s Fees
- Whether moral and exemplary damages and attorney’s fees were properly awarded.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)