Title
Vda. de Viray vs. Spouses Usi
Case
G.R. No. 192486
Decision Date
Nov 21, 2012
A dispute over the ownership of several parcels of land in Masantol, Pampanga is resolved by the Supreme Court, which reverses the ruling of the Court of Appeals and reinstates the decision of the Regional Trial Court, stating that the previous deeds of sale were valid and the petitioners had superior rights over the disputed land.
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Case Digest (G.R. No. 192486)

Facts:

  • The case involves several parcels of land in Masantol, Pampanga, initially part of Lot No. 733, Cad-305-D, under TCT 141-RP in the name of Ellen P. Mendoza.
  • On April 28, 1986, Geodetic Engineer Abdon G. Fajardo created a plan to subdivide Lot 733 into six parcels.
  • On April 29, 1986, Mendoza executed two deeds of absolute sale: Lot 733-F to Jesus Carlo Gerard Viray and Lot 733-A to spouses Avelino Viray and Margarita Masangcay, but these deeds were not annotated on TCT 141-RP.
  • Ruperta Cano Vda. de Viray, the surviving spouse of Jesus Viray, became involved after his death in April 1992.
  • On August 20, 1990, Mendoza, Emerenciana M. Vda. de Mallari, and spouses Jose and Amelita Usi executed a Subdivision Agreement (1st SA) using the Galang Plan, subdividing Lot 733 into three lots, resulting in new titles: TCT 1584-RP (Mallari), TCT 1585-RP (Usis), and TCT 1586-RP (Mendoza).
  • Another Subdivision Agreement (2nd SA) on April 5, 1991, further subdivided Lot 733-C into 13 smaller lots, resulting in titles TCT Nos. 1585-RP, 2092-RP, and 2101-RP for the Usis.
  • Legal actions followed, including suits for annulment of deeds of sale, forcible entry, and petitions for accion publiciana/reivindicatoria.
  • The RTC in Macabebe, Pampanga, dismissed the Usis' petition for accion publiciana/reivindicatoria, but the CA reversed this decision, declaring the Usis' ownership over the disputed lots.
  • The Supreme Court was petitioned to review the CA's decision.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court reversed and set aside the CA's decision.
  • Reinstated the RTC's dismissal of the Usis' petition for accion publiciana/reivindicatoria.
  • Ruled in favor of the petitioners.
  • Affirmed the validity of the April 29, 19...(Unlock)

Ratio:

  • The subdivision agreements were not genuine partitions among co-owners but were conveyances disguised as partitions.
  • The prior sale of Lot 733-A and Lot 733-...continue reading

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