Case Digest (G.R. No. 235725) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Binasoy Tamayao v. Lacambra, petitioners Felipa Binasoy Tamayao and the heirs of Rogelio Tamayao (collectively, the Spouses Tamayao) challenged the Court of Appeals (CA) and Regional Trial Court (RTC) rulings annulling the Extrajudicial Settlement of a Parcel of Land with Sale dated December 24, 1981 (third sale) and canceling Transfer Certificate of Title (TCT) No. T-54668 in their favor. The controversy arose from three consecutive transactions over Lot No. 2930 in Tuguegarao City: (1) a 1962 extrajudicial settlement and sale by Tomasa and Jose Balubal (heirs of Vicente Balubal) to Juan Lacambra, evidenced by a duly notarized public instrument but never registered on Original Certificate of Title (OCT) No. 6106; (2) a 1980 sale of a 5/14 undivided share by some heirs of Juan Lacambra to Rogelio Tamayao, annotated on OCT No. 6106; and (3) the 1981 extrajudicial settlement and sale of the entire Lot No. 2930 by the heirs of Balubal in favor of the Spouses Tamayao, which was r Case Digest (G.R. No. 235725) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Property
- Vicente Balubal owned Lot No. 2930 (922 sqm), covered by OCT No. 6106. Upon his death (c. 1944), his heirs were his children, Jose and Tomasa Balubal.
- Juan Lacambra purchased Lot No. 2930 in 1962; upon Juan’s death (1979), his heirs were Felipa, Natividad, Francisca, Sotero, Catalino, Cirilo Lacambra, and Basilio Coballes.
- Rogelio Tamayao (married to Felipa Binasoy) subsequently acquired interests in the same lot.
- Conveyance Transactions
- First Sale (Jan. 23, 1962)
- Extrajudicial Settlement and Sale by Jose and Tomasa Balubal to Juan Lacambra for ₱325.
- Notarized public instrument; not annotated on OCT 6106 but owner’s duplicate transferred to Juan.
- Second Sale (Jan. 21, 1980)
- Deed of Sale of an Undivided Share (5/14 or 329 sqm) by some heirs of Lacambra (except Cirilo and Catalino) to Rogelio Tamayao.
- Rogelio registered an adverse claim on OCT 6106 over that 5/14 share; he and wife built on the eastern portion.
- Third Sale (Dec. 24, 1981)
- Extrajudicial Settlement of a Parcel of Land with Sale by heirs of Balubal (Pedro Balubal, Tomasa, Leandro Andal) to Spouses Tamayao of the entire lot.
- Heirs of Balubal secured a new owner’s duplicate OCT 6106 (alleging loss); TCT No. T-54668 issued in Rogelio’s name.
- Litigation and Lower Court Rulings
- Civil Case No. 2986 (Mar. 21, 1982): Heirs of Lacambra sued to annul the third sale and cancel TCT T-54668.
- Civil Case No. 2989 (Apr. 7, 1982): Cirilo and Catalino Lacambra filed for legal redemption (joined for joint trial by RTC Order, Mar. 1, 1983).
- RTC Decision (Oct. 8, 2015):
- Declared first sale valid; Juan and heirs as owners (9/14) and Rogelio as owner of 5/14.
- Annulled third sale; canceled TCT T-54668; dismissed redemption suit.
- CA Decision (May 23, 2018) and Resolution (Jan. 14, 2019): Affirmed the RTC.
Issues:
- Did the CA err in upholding the validity of the first sale (1962) in favor of Juan Lacambra and his heirs?
- Did the CA err in annulling the third sale (1981) to Spouses Tamayao and in ordering cancellation of TCT No. T-54668?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)