Case Digest (G.R. No. 111547)
Facts:
- Petitioners: Trinidad S. Estonina and Paulino Estonina.
- Respondents: Court of Appeals, spouses Celso Atayan and Nilda Hicban, and heirs of Santiago Garcia.
- Dispute involves a 273 square meter parcel of land, Lot C of amended plan Psu-22983 Amd., in Barrio Santisima Cruz, Sta. Cruz, Laguna.
- Originally covered by Transfer Certificate of Title (TCT) No. T-19175, issued to Santiago Garcia, who died on October 2, 1967.
- On March 10, 1973, Trinidad Estonina obtained a writ of preliminary attachment against Consuelo Garcia, Santiago's widow, inscribing a notice on TCT No. T-19175.
- Series of transactions led to the cancellation of TCT No. T-19175 and issuance of TCT No. 77215, later cancelled for TCT No. 82229.
- On August 14, 1977, Santiago's children from his first marriage sold their shares to spouses Atayan, who later purchased shares from Consuelo Garcia and her children.
- Trinidad Estonina won a judgment in Civil Case No. 88430, leading to a public auction where he was the highest bidder.
- The Intermediate Appellate Court declared TCT No. T-82229 a nullity, resulting in TCT No. T-99961 issued to Trinidad Estonina.
- On July 25, 1985, spouses Atayan filed for annulment of the sheriff's sale and TCT No. T-99961, claiming ownership of their shares.
- The Regional Trial Court (RTC) dismissed their complaint, stating the property was conjugal and only Consuelo's share could be attached.
- The Court of Appeals reversed the RTC's decision, declaring the property as Santiago's exclusive property and ordering cancellation of TCT No. T-99961.
Issue:
- (Unlock)
Ruling:
- The Supreme Court denied the petition by the spouses Estonina and affirmed the Court of Appea...(Unlock)
Ratio:
- The Supreme Court stated that the factual findings of the Court of Appeals are generally conclusive, especially when conflicting with the trial court's findings.
- The Court of Appeals correctly identified the property as Santiago Garcia's exclusive property, inherited from his mother and not acquired during his marriage to Consuelo Garcia.
- Article 160 of the Civil Code presumes that property acquired during marriage belongs to the conjugal partnership only if proven to ...continue reading
Case Digest (G.R. No. 111547)
Facts:
The case involves the petitioners, Trinidad S. Estonina and Paulino Estonina, against the respondents, the Court of Appeals, spouses Celso Atayan and Nilda Hicban, and several heirs of Santiago Garcia. The controversy centers on a parcel of land, Lot C of the amended plan Psu-22983 Amd., located in Barrio Santisima Cruz, Sta. Cruz, Laguna, with an area of 273 square meters. This land was originally covered by Transfer Certificate of Title (TCT) No. T-19175, issued in the name of Santiago Garcia, who passed away on October 2, 1967.
On March 10, 1973, the Court of First Instance of Manila granted Trinidad Estonina a writ of preliminary attachment in Civil Case No. 88430 against Consuelo Garcia, Santiago's widow. A notice of attachment was inscribed on TCT No. T-19175, covering Consuelo's rights to the property. Following a series of transactions, including a sale of a portion of the land to Anselmo Balasoto, TCT No. T-19175 was cancelled, and TCT No. 77215 was issued for the remaining 213 square meters. This title was later cancelled due to another sale to Ofelia Garcia, resulting in TCT No. 82229 being issued.
On August 14, 1977, Santiago Garcia's children from his first marriage sold their pro indiviso shares to the spouses Atayan. Subsequently, Consuelo Garcia and her children sold their shares to the same spouses. After Trinidad Estonina won a favorable judgment in Civil Case No. 88430, the property was sold at a public auction, with Trinidad as the highest bidder. The Intermediate Appellate Court later declared TCT No. T-82229 a nullity, leading to the issuance of TCT No. T-99961 in favor of Trinidad Estonina.
On July 25, 1985, the spouses Atayan filed a complai...