Case Digest (G.R. No. 158929)
Facts:
Rosario P. Tan v. Artemio G. Ramirez, et al., G.R. No. 158929, August 03, 2010, the Supreme Court Third Division, Brion, J., writing for the Court. Petitioner Rosario P. Tan (representing her parents Crispo and Nicomedesa P. Alumbro) sued respondents Artemio G. Ramirez, Moises G. Ramirez, Rodrigo G. Ramirez, Domingo G. Ramirez, and Modesta Ramirez Andrade for recovery of ownership and possession and/or quieting of title over an 86,433-square meter parcel (Cadastral Lot No. 3483, Case 12, CAD 637-D, Inopacan Cadastre) located in Mahaba, Apid, Inopacan, Leyte (the subject property).The petition filed in the Municipal Circuit Trial Court (MCTC) of Hindang-Inopacan, Leyte on August 11, 1998 alleged title descent from petitioner’s great-grandfather Catalino Jaca Valenzona (TD No. 2724, 1915) through his daughter Gliceria, and then by succession and transfers to petitioner’s mother Nicomedesa. The factual account recited that Nicomedesa sold one-half of the property to Roberto (respondents’ predecessor) in 1965 and that Roberto had reflected the whole property under his tax declaration (TD No. 4193) since 1974.
Respondents traced title to Gavino Oyao and averred that Roberto purchased portions from Gavino’s heirs (Ronito and Wilfredo Oyao) and later from a certain Santa Belacho, who in 1975 had filed Civil Case No. B-565 claiming the subject property as Gavino’s natural child. The record shows a contract of sale from Belacho to Roberto dated September 16, 1977 and a Compromise Agreement dated October 5, 1977 settling Civil Case No. B-565 for P1,800.00, with Belacho waiving interest in favor of Roberto.
The MCTC (Decision dated April 2, 2001) held that the petitioner was entitled to one-fourth of the subject property and the respondents three-fourths, rejecting respondents’ prescription claim because of bad faith and insufficient period for extraordinary prescription. On appeal, the Regional Trial Court (RTC), Branch 18, Hilongos (Judge Abraham B. Apostol), issued a Decision dated June 29, 2001 adopting the MCTC decision but amending the shares to plaintiff one-third and defendants two-thirds; the RTC’s dispositive language was terse and lacked a detailed statement of facts and law.
Respondents petitioned the Court of Appeals (CA) via Rule 42 (CA-G.R. SP No. 66120). The CA, in a Decision dated January 28, 2003, set aside the MCTC and RTC decisions and declared Roberto the lawful owner of the entire subject property, reasoning that the 1977 compromise agreement and the September 16, 1977 contract of sale rendered Roberto a possessor in good faith with just title and that twenty-one years’ possession (1977–1998) sufficed for ordinary acquisitive prescription. Th...(Subscriber-Only)
Issues:
- Did the Court of Appeals err in holding that respondents acquired ownership of the subject property by ordinary acquisitive prescription based on the 1977 compromise agreement and the September 16, 1977 contract of sale (i.e., were respondents possessors in good faith and with just title)?
- Did the Regional Trial Court’s decision satisfy the constitutional and procedural requirement to state clearly and distinctly the facts and the law on which its judgment is based (Art. VIII, Sec. 14, 1987 Cons...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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