Case Digest (G.R. No. 122134) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In 459 Phil. 247 (G.R. No. 122134, October 3, 2003), the property in question is a 4,876-square-meter parcel in Urdaneta, Pangasinan, originally titled under O.C.T. No. 18383 (October 3, 1917) to spouses Herminigildo and Raymunda Locquiao. On May 22, 1944, the couple executed an Inventario Ti Sagut, a deed of donation propter nuptias in Ilocano, in favor of their son Benito A. Locquiao and his fiancée, Tomasa Mara, in consideration of their impending marriage (solemnized June 4, 1944 and noted on the back of the title). The donor-parents died in 1962 and 1968, leaving six heirs: Benito, Marciano, Lucio, Emeteria, Anastacia, and Romana Locquiao. With Benito and Tomasa’s permission, Romana Valencia occupied and tilled the land, later succeeded by her daughter, Constancia L. Valencia. Meanwhile, Benito and Tomasa registered the Inventario Ti Sagut on May 15, 1970, and secured Transfer Certificate of Title No. 84897. In 1973, the heirs (including Benito and Romana) executed a Deed o Case Digest (G.R. No. 122134) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Property origin and donation
- Herminigildo and Raymunda Locquiao were registered owners of a 4,876 sqm parcel in Urdaneta, Pangasinan (OCT No. 18383, issued 3 October 1917).
- On 22 May 1944 they executed in Ilocano an Inventario Ti Sagut (deed of donation propter nuptias) in favor of their son Benito and his fiancée Tomasa, gifting four parcels (including the subject land), a male cow, and one-third of the conjugal house, in consideration of the impending marriage solemnized on 4 June 1944 (annotated on OCT No. 18383).
- Heirs’ transactions and registrations
- Upon the donors’ deaths (1962 and 1968), six children remained heirs, among them Benito, Romana, and Constancia Valencia. With Benito and Tomasa’s consent, Romana took possession and cultivated the land; in 1977 her daughter Constancia assumed cultivation.
- The Inventario Ti Sagut was registered on 15 May 1970, cancelling OCT No. 18383 and issuing TCT No. 84897 to Benito and Tomasa. On 18 March 1973, all heirs executed a Deed of Partition with Recognition of Rights, distributing twelve parcels among three heirs and expressly excluding lands already donated; on 12 June 1976 those heirs (including Benito and Romana) signed a Deed of Compromise Agreement redistributing two other lots and reaffirming the partition.
- Judicial proceedings
- In 1983 Constancia filed an annulment-of-title action before the RTC, which was dismissed (no stated reason). On 13 December 1983 Benito sued Constancia for ejectment in the MTC; on 25 November 1985 she was ordered to vacate.
- On 23 December 1985 Romana and Constancia filed before the RTC a complaint to annul TCT No. 84897, alleging fraud, a spurious Inventario Ti Sagut, invalid notarization, and lack of acceptance in the donation. The RTC consolidated the ejectment and annulment cases, and on 30 January 1989 dismissed the annulment for prescription and laches, upheld the donation’s validity, and affirmed the ejectment. The Court of Appeals on 24 November 1994 affirmed these rulings, denied a motion for reconsideration on 8 September 1995, prompting this petition.
Issues:
- Validity of the donation propter nuptias
- Is the Inventario Ti Sagut authentic and duly executed?
- Was acceptance by the donees required, and if so, in what form?
- Timeliness of petitioners’ action
- What prescriptive period applies to an action to annul a title or reconvey property?
- Does laches independently bar the petitioners’ relief?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)