Case Digest (G.R. No. 95748) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Anastacia Vda. de Aviles, et al. v. Court of Appeals and Camilo Aviles, G.R. No. 95748 decided on November 21, 1996, petitioners‐heirs of Eduardo Aviles sued respondent Camilo Aviles in the Regional Trial Court (Branch 38, Lingayen, Pangasinan) for quieting of title over an 18,900‐square‐meter fishpond, cogonal, unirrigated rice and residential parcel in Malawa, Lingayen. Eduardo Aviles had possessed and mortgaged the property since 1957, and after foreclosure his mother redeemed it. On March 23, 1983, Camilo allegedly erected a bamboo fence and altered earthen dikes, claiming approximately 1,200 square meters as his own. Both parties relied on a 1957 partition agreement that allotted Eduardo 16,111 sqm, Anastacio 16,214 sqm, and Camilo 14,470 sqm—with Camilo presently in possession of only 12,686 sqm as shown by tax declarations. The trial court dismissed the complaint for lack of basis, ordered a Bureau of Lands survey to fix Camilo’s boundary,... Case Digest (G.R. No. 95748) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Property
- Plaintiffs: Anastacia Vda. de Aviles and siblings as heirs of Eduardo Aviles, actual possessors since 1957 of an 18,900 sq. m. parcel in Malawa, Lingayen, Pangasinan (Tax Decl. No. 31446).
- Defendants: Camilo Aviles (brother) and boundary neighbors Juana and Apolonio Joaquin.
- Partition and Possession History
- June 8, 1957 agreement of partition among Ireneo and Anastacia’s heirs: Eduardo allotted ~16,111 sq. m.; Anastacio ~16,214 sq. m.; Camilo ~14,470 sq. m.
- Eduardo mortgaged the property, foreclosed, then redeemed by his wife (plaintiffs’ mother) and declared in her name.
- Disputed Encroachment
- In March 1983, Camilo asserted color of title over ~1,200 sq. m. at the northern boundary by erecting a bamboo fence and moving earthen dikes.
- Camilo admits the partition agreement but claims the boundary fence merely “repaired the old fence”; his tax declarations Nos. 23575, 481, 379 (from 1958) cover 14,470 sq. m., though he actually occupies 12,686 sq. m.
- Trial Court Proceedings
- Trial court ordered the Bureau of Lands surveyor to relocate and fix Camilo’s southern boundary for his 14,470 sq. m. share.
- Complaint for quieting of title dismissed for lack of merit; plaintiffs ordered to pay Camilo ₱2,000 attorney’s fees and costs.
- Court of Appeals Decision
- Affirmed dismissal: held that quieting of title is not the proper remedy for boundary disputes (ejectment appropriate).
- Reversed surveyor-ordering clause of the trial court decision.
Issues:
- Proper Remedy
- Is a special civil action for quieting of title under Rule 64 the proper remedy to settle a boundary dispute, or should ejectment have been filed?
- Determination of Rights
- Should the Court of Appeals have fully declared the respective rights of the parties over the disputed parcel?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)