Case Digest (G.R. No. 208450) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Spouses Roberto Aboitiz and Maria Cristina Cabarrus v. Spouses Peter L. Po and Victoria L. Po, decided on June 5, 2017 under G.R. Nos. 208450 and 208497, the dispute arose over Lot No. 2835 in Cabancalan, Mandaue City, originally registered as OCT No. 0-887 in the name of Roberto Aboitiz. The property descended from Mariano Seno, who sold it in 1973 to his son Ciriaco. In May 1978, Ciriaco executed a Deed of Absolute Sale over Lot 2835 and Lot 2807 in favor of the Spouses Po, who thereafter declared the lot for taxation in 1991. Meanwhile, in 1990 the Mariano heirs, including Ciriaco, conveyed the same parcel to Roberto Aboitiz, who applied for original registration in April 1993. The RTC of Mandaue City (Branch 55) in November 2009 ruled in favor of the Spouses Po, declaring them the lawful owners and ordering reconveyance of the land and cancellation of Aboitiz’s title. The Court of Appeals partly affirmed this decision on October 31, 2012 but protected the titles of innoce Case Digest (G.R. No. 208450) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Proceedings
- Two consolidated petitions:
- G.R. No. 208450 – Spouses Roberto Aboitiz and Maria Cristina Cabarrus (Spouses Aboitiz) vs. Spouses Peter L. Po and Victoria L. Po (Spouses Po)
- G.R. No. 208497 – Spouses Po vs. Spouses Aboitiz, Jose Maria Moraza, Ernesto Aboitiz and Isabel Aboitiz
- Lower court decisions:
- RTC Mandaue City Branch 55 (Nov. 23, 2009) – Declared Spouses Po rightful owners; nullified Spouses Aboitiz titles but protected third-party titles
- CA Cebu City (Oct. 31, 2012; June 17, 2013) – Affirmed Po ownership; affirmed innocent-purchaser status of Jose, Ernesto, Isabel
- Land and Title History
- Original registration: Lot 2835 in Cabancalan, Mandaue City, under Mariano Seno
- July 31, 1973 – Mariano sold Lots 2807 & 2835 to son Ciriaco Seno
- May 5, 1978 – Ciriaco sold same two lots to Victoria Po by Deed of Absolute Sale
- Competing Transactions and Declarations
- July 15, 1982 – Mariano died, survived by five heirs (including Ciriaco)
- 1990 – Ciriaco quitclaimed Lot 2807 to Roberto; executed Memorandum of Agreement with Spouses Po re adjustment of consideration
- 1990 – Mariano’s heirs (excluding Ciriaco) sold Lot 2835 to Roberto Aboitiz; subdivision “North Town Homes” developed
- 1991–1992 – Tax Declarations issued: No. 0634-A in Po names; No. 1100 in Aboitiz name (annotated as duplicate)
- Torrens Registration and Suit for Reconveyance
- Apr. 19, 1993 – Roberto applied for original registration (LRC Case No. N-208); Oct. 28, 1993 – OCT No. 0-887 issued to Roberto
- Subdivision parcels sold to Ernesto and Jose
- Nov. 19, 1996 – Spouses Po filed reconveyance and cancellation suit in RTC Mandaue City (Branch 55)
- 2009–2013 – RTC and CA decisions, followed by SC Rule 45 petitions
Issues:
- Whether the RTC had jurisdiction over the Spouses Po’s reconveyance and cancellation complaint
- Whether Spouses Po’s cause of action had prescribed
- Whether estoppel or laches barred Spouses Po’s action
- Whether the LRC Case No. N-208 finding (that Ciriaco held in trust for the heirs) bars Po’s reconveyance suit under res judicata
- Whether the 1978 Deed of Absolute Sale (Ciriaco→Spouses Po) is fake/fraudulent or inadmissible
- Whether Mariano’s heirs are indispensable parties in the reconveyance action
- Whether respondents Jose, Ernesto, and Isabel are innocent purchasers in good faith
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)