Case Digest (G.R. No. 121027) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Dezoller Tison v. Court of Appeals, petitioners Corazon Dezoller Tison and Rene R. Dezoller, niece and nephew of the late Teodora Dezoller Guerrero, sought reconveyance of a parcel of land with improvements in San Francisco del Monte, Quezon City. Teodora died on March 5, 1983, without ascendants or descendants and survived only by her husband, Martin Guerrero, and the petitioners—her brother’s children by right of representation. On September 15, 1986, Martin executed an Extrajudicial Settlement of Estate, purportedly as sole heir, over the property covered by Transfer Certificate of Title (TCT) No. 66886, resulting in the issuance of TCT No. 358074 in his name. On January 2, 1988, Martin sold the entire lot to private respondent Teodora Domingo, who obtained TCT No. 374012, and he died on October 25, 1988. Thereafter, on November 2, 1988, petitioners filed Civil Case No. Q-88-1054 in the Regional Trial Court (RTC) of Quezon City, Branch 98, claiming half of the property by Case Digest (G.R. No. 121027) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Relationship
- Petitioners: Corazon Dezoller Tison and Rene R. Dezoller, niece and nephew of the late Teodora Dezoller Guerrero
- Private Respondent: Teodora Domingo, purchaser of the disputed property
- Subject Property and Title Transfers
- Original Ownership: Parcel with house and apartment in San Francisco del Monte, Quezon City, titled under TCT No. 66886 in the names of spouses Martin Guerrero and Teodora Dezoller Guerrero
- Extrajudicial Settlement: September 15, 1986, Martin Guerrero executed an Affidavit of Extrajudicial Settlement as sole heir; TCT No. 358074 issued in his name
- Sale to Respondent: January 2, 1988, Martin Guerrero sold the property to Teodora Domingo; TCT No. 374012 issued to her
- Trial and Appellate Proceedings
- November 2, 1988: Petitioners filed an action for reconveyance in RTC Quezon City (Civil Case No. Q-88-1054), claiming one-half share by right of representation
- Petitioners presented testimony and documentary evidence on filiation; respondent filed a Demurrer to Plaintiff’s Evidence for failure to prove legitimate filiation under Article 172, Family Code
- December 3, 1992: RTC granted the demurrer and dismissed the complaint; June 30, 1995: Court of Appeals affirmed; July 31, 1997: Petition for certiorari to the Supreme Court
Issues:
- Legitimacy and Collateral Attack
- Can petitioners’ legitimacy be attacked collaterally in an action for reconveyance?
- Filiation Proof
- Did petitioners establish their relationship as niece and nephew of Teodora Dezoller Guerrero sufficient to support inheritance by right of representation?
- Property Share and Co-ownership
- What legal shares do petitioners and private respondent hold in the subject property under the Civil Code?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)