Case Digest (G.R. No. 181359) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Spouses Clemencio C. Sabitsana, Jr. and Ma. Rosario M. Sabitsana v. Juanito F. Muertegui (G.R. No. 181359, August 5, 2013), Alberto Garcia executed an unnotarized Deed of Sale on September 2, 1981, conveying a 7,500-sqm unregistered parcel in Dalutan Island, Biliran, to Juanito Muertegui. Juanito’s father and brother took possession, planted coconut and ipil-ipil trees, and paid taxes from 1980 to 1998. Ten years later, on October 17, 1991, Garcia sold the same lot to his family lawyer, Atty. Clemencio Sabitsana, Jr., via a notarized deed, registered February 6, 1992, and a new Tax Declaration No. 5327 issued in Sabitsana’s name. In 1998, when Muertegui Sr. died, his heirs applied to register the lot under the Public Land Act; Sabitsana opposed in writing, claiming ownership. On April 11, 2000, Juanito filed Civil Case No. B-1097 for quieting of title and injunction, seeking to void Sabitsana’s deed, letter opposition, and Tax Declaration, and prayed for damages and attorney’ Case Digest (G.R. No. 181359) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Initial Transactions and Possession
- On September 2, 1981, Alberto Garcia executed an unnotarized Deed of Sale in favor of Juanito F. Muertegui over a 7,500 sqm unregistered parcel in Dalutan Island, Biliran.
- Juanito’s father and brother entered actual, public, adverse, continuous possession; planted coconut and ipil-ipil; and paid real property taxes (1980–1998).
- Subsequent Sale to Petitioners
- On October 17, 1991, Garcia sold the same lot to his lawyer, Atty. Clemencio C. Sabitsana, Jr., via a notarized Deed of Absolute Sale; registered February 6, 1992; and secured Tax Declaration No. 5327.
- Petitioners made improvements (rip-rap in 1996–1997) and paid taxes sporadically (1992, 1993, 1999).
- Opposition and Litigation
- In August 1998, Atty. Sabitsana opposed the Muertegui heirs’ application for public land registration, claiming conflicting ownership.
- On April 11, 2000, Juanito (through attorney-in-fact Domingo Jr.) filed Civil Case No. B-1097 for quieting of title and preliminary injunction, praying to nullify petitioners’ sale, letter, and TD No. 5327, and for damages and attorney’s fees.
- Trial Court Proceedings
- Petitioners counterclaimed: argued lack of marital consent, good faith purchase, prescription, laches, and lack of jurisdiction (assessed value ₱1,230).
- RTC Decision (Oct. 28, 2002): Declared the 1981 sale valid; 1991 sale and TD No. 5327 void for bad faith; awarded Juanito attorney’s fees (₱30,000), litigation expenses (₱10,000), and costs.
- Court of Appeals Review
- CA affirmed RTC (Jan. 25, 2007): held 1981 sale voidable but not annulled, thus valid; applied Art. 1544, preferred first possessor in good faith; found petitioners acted in bad faith; awarded fees and costs.
- Petitioners’ Motion for Reconsideration denied (Jan. 11, 2008).
Issues:
- Jurisdiction of the RTC
- Whether the RTC lacked jurisdiction given the low assessed value (₱1,230).
- Applicable Registration Rule
- Whether Art. 1544 (Civil Code) or PD No. 1529 governs double sale of unregistered land.
- Prescription, Laches, and Estoppel
- Whether Juanito’s delay (1991–1998) barred his quieting action.
- Award of Attorney’s Fees and Expenses
- Whether such award was proper absent bad faith.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)