Case Summary (G.R. No. 114151)
Applicable Law
The applicable law includes the 1987 Philippine Constitution, relevant provisions of the Civil Code, particularly Articles 1078, 493, and 1088, and the Rules of Court governing actions for quieting of title, partition of estates, and the extrajudicial settlement of estates.
Background of the Case
Upon the death of Jacinto and Enrica Alejandrino, their six children, including Mauricia, were entitled to a 219-square-meter lot, with each child’s share approximately 36.50 square meters. However, the estate was not properly settled. Over time, Mauricia acquired additional shares from her siblings, claiming ownership of 97.43 square meters, while Licerio Nique also acquired shares from the same siblings, totaling 121.67 square meters.
Trail Court's Decision and Appeal
The Regional Trial Court of Cebu City ruled in favor of Nique in a separate case, affirming his ownership of the shares acquired from Laurencia Alejandrino and ordering her to vacate the premises. Laurencia subsequently withdrew her appeal to the Court of Appeals, leaving the trial court's decision final. Following this, Mauricia filed a separate complaint against Nique seeking redemption and recovery of her shares, which was later admitted by the court.
Order for Segregation of Property
Nique filed a motion for the segregation of his claimed 146 square meters of Lot No. 2798, which was granted by the trial court on May 6, 1993. The court determined that the segregation was in accordance with its previous ruling and the existing extrajudicial settlement executed between Mauricia and Laurencia. The trial court asserted that it had jurisdiction to order this segregation as it fell within the context of executing a final judgment.
Court of Appeals Ruling
Mauricia appealed the trial court's order to the Court of Appeals, arguing that the lower court exceeded its jurisdiction in ordering the segregation as this was not explicitly stated in the trial court's final decision. The appellate court dismissed her petition, explaining that the trial court was merely executing its decision and that the existence of the extrajudicial settlement justified the segregation of property.
Arguments and Counterarguments
Mauricia contended that the extrajudicial settlement was invalid due to lack of notarization and that she was not bound by its stipulations as she was not a defendant in the original quieting of title case. In contrast, Nique argued that Mauricia was estopped from questioning the settlement due to her knowledge of the prior proceedings and the lack of any new ground for reconsideration in the appellate court.
Legal Interpretation
Under Article 1078 of the Civil Code, heirs share ownership of the decedent's estate before partition. While Laurencia’s sale of her pro indiviso share was within her rights, the s
...continue readingCase Syllabus (G.R. No. 114151)
Background of the Case
- The case involves a petition for review on certiorari challenging the Decision of the Court of Appeals.
- The core issue revolves around the trial court's jurisdiction in ordering the segregation of property in an action for quieting of title after the court's decision had become final.
Facts of the Case
- The late spouses Jacinto Alejandrino and Enrica Labunos bequeathed a 219-square-meter lot in Mambaling, Cebu City, identified as Lot No. 2798, to their six children: Marcelino, Gregorio, Ciriaco, Mauricia, Laurencia, and Abundio.
- Each child was entitled to a share of 36.50 square meters of the property.
- Petitioner Mauricia Alejandrino claimed to have purchased additional shares from her siblings, totaling 97.43 square meters.
- Private respondent Licerio Nique also purchased portions of the property from various siblings, amounting to 121.67 square meters.
Procedural History
- Laurencia Alejandrino filed a lawsuit (Civil Case No. CEB-7038) against Nique regarding the sale of property portions.
- The trial court ruled in favor of Nique, declaring him the owner of specific shares of the property.
- Laurencia withdrew her appeal against this decision, which subsequently became final.
- Mauricia filed another suit (Civil Case No. CEB-11673) agains