Case Digest (G.R. No. 144095)
Facts:
Spouses Haymaton S. Garingan and Jayyari Pawaki v. Hadji Munib Saupi Garingan, Hadja Tero Saupi Garingan, and Hadja Jehada Saupi Garingan, G.R. No. 144095, April 12, 2005, the Supreme Court First Division, Carpio, J., writing for the Court.On 23 February 1993, Hadji Munib, et al. filed a complaint for Partition and Injunction with prayer for Preliminary Injunction in the Third Shari'a Judicial District, Zamboanga City (Civil Case No. 13-3) against their sister Haymaton Saupi Garingan and her husband Jayyari Pawaki (also known as Djayari Moro). Plaintiffs alleged that their grandfather, Saupi Moro, had acquired an agricultural parcel in Sitio Tinebbasan, Barangay Semut, Lamitan, Basilan, and had donated it to his daughter Insih Saupi, whose hereditary rights passed to her children (the plaintiffs and Haymaton) upon her death.
The Shari'a District Court (Acting Presiding Judge Bensaudi I. Arabani, Sr.) found that Saupi Moro donated the land to Insih, that Insih predeceased Saupi Moro, and that her children succeeded to her rights; the court concluded an implied trust existed between the co-heirs and Haymaton (and her husband), ordered partition of the parcel into equal fourths among the four siblings, annulled Transfer Certificate of Title (TCT) No. T-2592 in the name of Djayari/Javyari Moro, and directed issuance of new titles in the heirs’ names (Decision dated 19 June 2000). The Shari'a District Court denied petitioners’ motion for reconsideration on 19 July 2000.
Petitioners brought the matter to the Supreme Court by a petition for review under Rule 45 of the Rules of Court, challenging (1) the Shari'a District Court's cancellation of TCT No. T-2592 and partition order notwithstanding Torrens protection; (2) the court’s failure to find respondents’ claim barred by prescription or laches; and (3) respondents’ alleged lack of standing to sue for partition because petitioners were sole owners. The petition presented extensive title and chain-of-title facts: the land had been the subject of a homestead application by Andaang Gani, Letters of Patent No. V-41831 were issued on 17 February 1955, OCT No. P-793 was issued 6 December 1955, and the title was later transmitted by sale into TCT No. T-2592 in the name of Djayari Moro (registered as of 10 June 1971). Earlier proceedings included Civil Case No. 31 (illegal detainer) against Saupi Moro, dismissed in 1951, and Civil Case No. 41 (annulment of title) filed in July 1956 and later abandoned after court records were destroyed by fire.
...(Pro-only)Issues:
- Did the Shari'a District Court err in ordering partition of the subject property and annulment of Transfer Certificate of Title No. T-2592 by relying on respondents' claim of ancestral ownership while disregarding the protection accorded to Torrens titles?
- Did the Shari'a District Court err in failing to rule that respondents' right to seek reconveyance of the subject property had prescribed or was barred by laches?
- Did the Shari'a District Court err in failing to rule that respondents had no cause of action for partition because they were ...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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