Case Digest (G.R. No. 167798) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Spouses Yu Hwa Ping and Mary Gaw v. Ayala Land, Inc. (G.R. Nos. 173120 & 173141, July 26, 2017), the petitioners trace their title to a March 17, 1921 survey plan (PSU-25909) approved May 26, 1921 by the Director of Lands in favor of Spouses Andres Diaz and Josefa Mia covering 460,626 sqm in Las Piñas, Rizal. Subsequent surveys over the same parcel—PSU-47035 (October 21, 1925), PSU-80886 (July 28, 1930) and PSU-80886/SWO-20609 (March 6, 1931)—issued original certificates of title (OCT) Nos. 1609 (1958) and 242/244 (1950) to successors Mayuga, Guico and Yaptinchay. In 1968, Diaz secured OCT No. 8510 for Lot 1 under PSU-25909, subdivided into Lots 1-A to 1-J in 1970 and partly sold to Librado Cabautan in 1976. Spouses Yu acquired Lot 1-A (67,813 sqm) in 1993 and Lot 1-B (135,000 sqm) in 1994, resulting in TCT Nos. 39408 and 64549. Meanwhile, respondent Ayala Land, Inc. (ALI) holds overlapping TCTs Nos. 41325, 41263, 41262 and 41261 by virtue of mergers from CPJ Corporation and Case Digest (G.R. No. 167798) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Survey Plans and Titles
- March 17, 1921 – Psu-25909 by A.N. Feliciano for Spouses Andres Diaz and Josefa Mia (Lot 1, 460,626 m²) approved May 26, 1921.
- October 21, 1925 – Psu-47035 by A.N. Feliciano for Dominador Mayuga (Lot 3, 171,309 m²).
- July 28, 1930 – Psu-80886 by A.N. Feliciano for Eduardo C. Guico (Lot 2, 158,494 m²).
- March 6, 1931 – Psu-80886/SWO-20609 by A.N. Feliciano for Alberto Yaptinchay (subsequent work order).
- May 1950–May 1958 – Issuance of OCTs Nos. 242, 244, and 1609 covering Lots 2 and 3.
- Transfers and Registrations
- February 16, 1968 – Spouses Diaz apply for original registration of Lot 1 (Psu-25909); OCT No. 8510 issued May 19, 1970.
- May 1970 – Spouses Diaz subdivide OCT 8510 into Lots 1-A to 1-J and convey to third parties.
- 1976 – Sales to Librado Cabautan; new TCTs Nos. 287411–287416.
- 1993–1994 – Spouses Yu acquire half of Lot 1-A (TCT 39408) and Lot 1-B (TCT 64549).
- 1980–1992 – CPJ Corporation and successors convey Lots 2–3 to Ayala Land, Inc. (TCTs 41261–41263, 41325).
- Proceedings Below
- Diaz Case (RTC Pasig, 1995) – RTC cancels OCT 8510 for alleged fraud; CA initially affirms, then grants reconsideration, then reinstates cancellation in 2006.
- Yu Case (RTC Las Piñas, 2001) – RTC orders verification survey, finds Psu-47035, Psu-80886, Psu-80886/SWO-20609 spurious, voids ALI’s TCTs and upholds Spouses Yu’s TCTs; CA reverses, then amends to set aside ALI titles, then reinstates ALI titles in 2006.
Issues:
- Whether Spouses Yu’s complaint is barred by prescription.
- Whether the validity of OCTs 242, 244, and 1609 (ALI) as against OCT 8510 (Spouses Diaz/Yu) can be assailed.
- Whether Guico v. San Pedro is applicable to Psu-80886.
- Whether errors in Psu-80886 and Psu-47035 invalidate OCTs 242, 244, and 1609.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)