Case Digest (G.R. No. 28394)
Facts:
This case revolves around Engracio L. Valmonte et al. (Plaintiffs and Appellees) versus Pedro Villaroman (Defendant and Appellant). The dispute emerged from a claim concerning land that was inherited from Buenaventura Valmonte, who died in 1909, leaving behind a complex familial situation involving multiple heirs from two marriages. Following Buenaventura's death, his children from his first marriage and his second marriage sold a portion of the land to Pedro Villaroman on July 15, 1914, for a total price of P2,100. However, Villaroman defaulted on the remaining balance of P600, prompting the plaintiffs, the heirs, to initiate a lawsuit on February 14, 1926, for recovery of that balance.During the proceedings, it was revealed that some heirs, specifically Ambrosio Advincula who was in America, potentially had claims to the land since they had not participated in the sale. The trial court, after considering the evidence, ruled that the land described in the complaint was collec
Case Digest (G.R. No. 28394)
Facts:
- Background of the Case
- The case involves a dispute over the partition and ownership of a parcel of land originally belonging to Buenaventura Valmonte.
- The parties include:
- Plaintiffs/Appellees – Engracio L. Valmonte, Donata L. Valmonte, and Esperanza B. Valmonte (children of the deceased Doroteo Valmonte), along with their mother Constancia Linsangan.
- Defendant/Appellant – Pedro Villaroman, who is challenging the lower court’s decision.
- Other family members involved in the chain of title include heirs from Buenaventura Valmonte’s first marriage (Marcelino, Doroteo, Manuel Valmonte) and those from his second marriage (Dominga, Ignacia, Hipolito, and Maria Valmonte).
- Transaction and Sale of the Land
- Pedro Villaroman purchased the land on July 15, 1914, from certain of Buenaventura Valmonte’s heirs (Manuel, Dominga, Ignacia, Hipolito, and Maria Valmonte), under an agreement that involved:
- A total sales price of P2,100 with P1,100 payable at the execution of the deed, and the remaining P1,000 paid in installments (the balance of P600 became the subject of dispute).
- An arrangement indicating that the vendors provided a bond to secure the sale.
- After acquiring the land, Villaroman began cultivating it and, on October 21, 1914, declared it for land tax purposes.
- Dispute arose when Villaroman defaulted on the balance payment, leading to a suit for recovery of the unpaid portion.
- Meanwhile, some of Buenaventura Valmonte’s heirs (specifically, grandchildren through Doroteo, and Ambrosio Advincula, the son of Marcelino) asserted an interest in the property, complicating the transaction.
- Possession, Registration, and Subsequent Developments
- Villaroman’s possession:
- He took possession of the land in an open, peaceful, and adverse manner beginning July 15, 1914.
- His possession was evidenced further by the declaration for payment of land tax on October 21, 1914.
- Registration Process:
- Villaroman applied for and was adjudicated the land by the Court of First Instance of Nueva Ecija on November 29, 1923.
- The registration process culminated with the issuance of a decree on May 20, 1926, and a certificate of title on May 25, 1926, which was free from any annotation of encumbrance.
- Notice of Lis Pendens:
- Plaintiffs filed a notice of lis pendens to protect any rights they might have concerning the land.
- The notice aimed to secure their interests against third parties while the dispute was ongoing.
- Claims and Allegations
- Plaintiffs’ Claims:
- They sought a judicial partition of the land, with detailed proportions clearly set out based on the various familial shares.
- They requested that any income from the land since 1916 be accounted for and distributed proportionately.
- They also prayed for the appointment of a guardian ad litem for the minor heirs (Ricardo and Marcos Advincula).
- Appellant’s (Villaroman’s) Alleged Errors in the Trial Court Judgment:
- The trial court was alleged to have erred in finding that Villaroman was not in possession of the land as owner continuously, peacefully, publicly, and adversely since July 15, 1914.
- The court was also faulted for holding that his certificate of title obtained under the Land Registration Law was not conclusive against the whole world, thereby not barring an action for partition.
- Additional Context:
- There was controversy regarding whether all rightful heirs had been represented in the sale, particularly concerning the interests of the descendants of Doroteo and the whereabouts (and presumed death) of Ambrosio Advincula.
- Procedural History
- The trial court originally ordered the partition of the property among the coheirs, with specific proportions allocated to different parties.
- It also ordered that Pedro Villaroman render an account of the income from the land from 1916 onward.
- Pedro Villaroman, insisting on his exclusive ownership based on open and adverse possession, appealed the decision.
- The appellate decision reviewed issues of adverse possession, the binding nature of the certificate of title, and the effect of the notice of lis pendens.
Issues:
- Possession and Adverse Holding
- Whether Pedro Villaroman’s possession of the land, which was open, continuous, adverse, and as owner since July 15, 1914 (with tax declarations starting October 21, 1914), qualifies him to acquire title by prescription.
- Whether the possession was sufficiently uninterrupted and adverse to effectuate acquisitive prescription under Act No. 190.
- Conclusiveness of the Certificate of Title
- Whether the certificate of title obtained by Villaroman under the Land Registration Law is conclusive against all parties, including the other heirs who raised claims later.
- Whether such a certificate should bar any subsequent partition action brought by the coheirs not involved in the sale.
- Impact of Lis Pendens
- Whether the notice of lis pendens filed by the plaintiffs, which aims to safeguard their rights against third parties, affects the validity of the registered title in Villaroman’s name.
- Whether the timing of the lis pendens negates Villaroman’s adverse possession claim and registration.
- Subrogation and the Nature of the Sale
- Whether the sale from the selected heirs (Manuel, Dominga, Ignacia, Hipolito, and Maria Valmonte) to Villaroman, made under the bond security, subrogated Villaroman to the rights of all coheirs, including those who did not intervene.
- Whether the alleged error in the deed of sale or lack of waiver from certain heirs detracts from the validity of Villaroman’s possession and subsequent registration.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)