Case Digest (G.R. No. 147420) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In the case of Dr. Nixon L. Treyes v. Antonio L. Larlar, et al. (G.R. No. 232579, September 8, 2020), petitioner Dr. Nixon L. Treyes challenged the Court of Appeals’ August 18, 2016 Decision and June 1, 2017 Resolution affirming the Regional Trial Court (RTC) of San Carlos City, Branch 59, in Civil Case No. RTC-1226. On May 1, 2008, petitioner’s wife, Rosie Larlar Treyes, died intestate and childless, leaving seven siblings (respondents Antonio, Rev. Fr. Emilio, Heddy, Rene, Celeste, Judy, and Yvonne Larlar) as compulsory heirs under Article 1001 of the Civil Code. At death, Rosie and petitioner held fourteen (14) real estate parcels as conjugal property. Petitioner thereafter executed two Affidavits of Self-Adjudication (September 2, 2008; May 19, 2011), both registered—March 24, 2011 with the Marikina City Register of Deeds and June 5, 2011 with the San Carlos City, Negros Occidental Register of Deeds—transferring Rosie’s entire estate to himself as sole heir. Respondents’ let Case Digest (G.R. No. 147420) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Background
- On May 1, 2008, Rosie Larlar Treyes (Rosie) died intestate, childless, survived by her husband, Dr. Nixon L. Treyes (petitioner), and seven siblings (private respondents).
- At her death, Rosie and petitioner owned 14 real estate parcels as conjugal property.
- Self-Adjudication and Registration
- Petitioner executed two Affidavits of Self-Adjudication (Sept. 2, 2008; May 19, 2011) and registered them in Marikina City and San Carlos City.
- As a result, new Torrens titles covering the 14 parcels were issued in petitioner’s name, excluding Rosie’s siblings.
- Correspondence and Discovery
- Beginning Feb. 13, 2012, respondents wrote petitioner requesting an estate settlement conference, and again on April 3, 2012; petitioner did not respond.
- Respondents discovered the old titles cancelled and new ones issued in petitioner’s name.
- Trial Court Proceedings
- July 12, 2013: respondents filed a Complaint in RTC-1226 for
- Annulment of the two Affidavits of Self-Adjudication and cancellation of corresponding Torrens titles
- Reconveyance of respondents’ successional shares
- Partition of Rosie’s estate
- Moral and exemplary damages, attorney’s fees, and litigation expenses
- Petitioner’s first Motion to Dismiss (Oct. 25, 2013) for lack of personal jurisdiction; later perfected service.
- Second Motion to Dismiss (June 20, 2014) for improper venue, prescription, and lack of subject-matter jurisdiction; RTC denied it on July 15, 2014 but ordered partition cause of action dropped.
- Petitioner’s Omnibus Motion (July 28, 2014) for reconsideration and to defer answer; RTC denied (Aug. 27, 2014).
- Court of Appeals and Supreme Court
- Petitioner filed a Rule 65 certiorari petition with CA; CA denied it (Decision Aug. 18, 2016; Resolution June 1, 2017).
- Petitioner filed a Rule 45 petition for review on certiorari with the Supreme Court.
Issues:
- Jurisdictional Challenge
- Did the RTC gravely abuse its discretion in denying petitioner’s second Motion to Dismiss for lack of subject-matter jurisdiction?
- Is prior judicial determination of heirship in a special proceeding required before heirs can file an ordinary civil action to enforce successional rights?
- Venue and Prescription
- Was venue improperly laid in San Carlos City?
- Was the action barred by prescription at the time of filing?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)