Case Digest (G.R. No. 118069)
Facts:
Desamparados M. Soliva v. The Intestate Estate of Marcelo M. Villalba and Valenta Balicua Villalba, G.R. No. 154017, December 08, 2003, First Division, Panganiban, J., writing for the Court.
Petitioner Desamparados M. Soliva (substituted by her sole heir Perlita Soliva Galdo) sued for recovery of ownership, possession and damages against Valenta Balicua Villalba on May 5, 1982, alleging ownership of a titled agricultural lot and that her late husband had consented to and accepted P600.00 as part-payment when Capt. Marcelo M. Villalba occupied the house and lot on January 4, 1966; Captain Villalba died in 1978 without having paid the balance. Valenta was declared in default; the trial court, on March 26, 1984, restored Soliva to possession and awarded damages and attorney’s fees.
Valenta filed a petition for relief from judgment on June 5, 1984, claiming excusable confusion and a meritorious defense that Marcelo had paid P2,250.00 of the P3,500.00 purchase price. The trial court denied relief on September 3, 1984. The Court of Appeals (Third Division, penned by Justice Marina L. Buzon) reversed on February 21, 1990, finding excusable negligence and a meritorious defense, set aside the default judgment, and ordered substitution of the administrator of the intestate estate of Marcelo Villalba as defendant. Soliva amended her complaint to name the Intestate Estate, represented by its administrator Atty. Eleno M. Kabanlit.
At the resumed proceedings the estate and Valenta (as intervenor) asserted that the lot had been sold to Marcelo on December 18, 1965 for P3,500.00 and that P2,250.00 had been paid; Valenta also alleged long, continuous possession and substantial expenditures in improvements. On March 11, 1993 the trial court dismissed the complaint and counterclaims and ordered reconveyance of the lot to respondents. The Court of Appeals, in CA-G.R. CV No. 42024, affirmed that judgment in a Decision dated November 9, 2001 and denied Soliva’s motion for reconsideration in a Resolution dated May 23, 2002.
Soliva filed a p...(Subscriber-Only)
Issues:
- Is petitioner barred from recovering the disputed property by laches or prescription?
- If petitioner is barred from recovering the property, does ordering reconveyance to respondents without full payment of the purchase price result in unjust enrichment, and w...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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