Case Digest (G.R. No. 159571) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
The case involves a dispute over a parcel of land located in Tuburan Sur, Danao City, originally owned by Hilarion Derecho, who passed away long before World War II. His death led to the intestate succession of the property among his eight children: Leonardo, Apolinar, Andres, Honorata, Dolores, Gerardo, Agaton, and Oliva, who became pro indiviso co-owners of the subject land. Initially, Tax Declaration No. 00267 was issued under the name "Heirs of Hilarion." On July 16, 1921, five of the heirs sold the property to Francisco Lacambra, establishing a pacto de retro, which allowed them to redeem the property within five years. After failing to redeem by the deadline, Dolores and her husband, Leandro Rigonan, repurchased the land from Lacambra in 1928, occupying it immediately. Over fifty years of unchallenged possession followed.On April 24, 1980, Leandro executed an Affidavit of Adjudication declaring himself the sole heir of Hilarion, which prompted Teodoro Rigonan, Leandro&#
Case Digest (G.R. No. 159571) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
The controversy involves a parcel of land in Tuburan Sur, Danao City, originally owned by Hilarion Derecho. At his death before World War II, his eight children became co-owners by intestate succession. In 1921, five of the heirs sold the property to Francisco Lacambra under a pacto de retro sale, which allowed a five‐year redemption period. Not all heirs participated in this sale, and when the redemption period lapsed in 1926, Lacambra acquired absolute title. In 1928, Dolores Derecho, one of the heirs, together with her husband Leandro Rigonan, repurchased the land from Lacambra and took possession in their personal capacity, arguing that the co-ownership had effectively terminated with the expiry of the redemption period. Later, Leandro executed an Affidavit of Adjudication naming himself as the sole heir, and his son Teodoro obtained tax declarations—further reinforcing the possession and title. Teodoro subsequently mortgaged and sold the property to Valerio Laude, who took further steps to perfect the title. Decades later, respondents (the remaining heirs, and their successors) filed an action to annul the void contracts and recover their shares, claiming fraud in the earlier transactions. However, the petitioners maintained that their continuous and adverse possession of the property since 1928 had acquired title by prescription and that respondents’ long inaction (over 65 years) barred their claims via both prescription and the equitable doctrine of laches.Issues:
- Whether co-ownership among the heirs of Hilarion Derecho subsisted at the time of the 1928 purchase or terminated with the expiry of the redemption period under the pacto de retro sale.
- Whether an implied trust arose from the repurchase transaction by the Rigonan spouses, thereby obligating them to hold the property partly in trust for the other co-heirs.
- Whether the respondents’ claims, including the action to annul the fraudulent sale and affidavit, are barred by prescription and/or laches given their prolonged inaction.
- Whether Petitioner Valerio Laude, having taken notice of the property’s co-ownership status, can be considered a bona fide buyer in good faith.
- Whether the resolution awarding litigation expenses and attorney’s fees constituted an abuse of discretion, particularly in light of the parties’ respective inactions and the doctrine of laches.
- Whether the lower court’s ruling on the issue of heirship was erroneous in light of the implications of the co-ownership termination.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)