Case Summary (G.R. No. 242127)
Background
The case originated from a complaint filed by Rosello Calignawan, asserting ownership over certain properties upon the grounds of a Deed of Donation executed by Angeles Engao Calignawan, which he later claimed to be valid. The properties in question were originally registered under the names of Romana and Angeles. Following the death of Romana, Angeles purportedly inherited three-fourths of the properties, with the remaining one-fourth going to her brother, Felipe Engao. Rosello alleged that he had a valid claim based on the aforementioned donation, which was contested by the petitioners.
Regional Trial Court Ruling
The Regional Trial Court (RTC) ruled on December 16, 2009, declaring that the properties belonged to Romana and Angeles, not to the spouses Cesario and Romana Engao. It invalidated the Deed of Donation on several grounds, including questions regarding Angeles' mental and physical capacity when she signed it, evidencing that the signature was inconsistent with her previous signatures, and noting discrepancies in the notarization process.
Court of Appeals Decision
On January 18, 2018, the Court of Appeals reversed the RTC's ruling, validating the Deed of Donation in favor of Rosello and classifying the RTC's earlier documents—including a Deed of Adjudication and other related instruments—as null and void. The appellate court relied on the principle of res judicata, asserting that the validity of the Deed of Donation had already been established in a prior case.
Legal Issues Raised
Petitioners contested both the appellate court’s acceptance of the appeal and the validity inherent in the Deed of Donation, arguing that Rosello violated forum shopping principles by pursuing two separate but related actions in different jurisdictions. They contended that the RTC of Tacloban’s judgment took precedence due to its earlier submission and ruling over the matter.
Supreme Court Ruling
The Supreme Court denied the petition, affirming the Court of Appeals’ decision. It reasoned that the issue of forum shopping was raised too late since petitioners actively participated in the RTC of Burauen's proceedings without voicing their concerns a
...continue readingCase Syllabus (G.R. No. 242127)
Background of the Case
- The petitioners, comprising Evangeline Engao Asis, heirs of Felicitation Engao-Bautista, heirs of Erma Engao Trocino, and Cesar A. Engao, filed a Petition for Review against the respondents, heirs of Rosello Calignawan.
- The petition challenges the January 18, 2018 Decision of the Court of Appeals (CA), which reversed the December 16, 2009 Decision of the Regional Trial Court (RTC) in Tacloban City.
- The RTC had previously ruled on a case involving the declaration of nullity of documents, partition, and damages concerning properties registered under the names of Romana and Angeles Engao.
Antecedents of the Case
- The Spouses Cesario and Romana Engao had two children: Felipe Engao and Angeles Engao-Calignawan.
- The properties in dispute are Lot No. 581 and Lot No. 2064 in Tacloban City, originally covered by TCT No. T-1084 and TCT No. T-1051.
- Rosello Calignawan, the father of the respondents, claimed a portion of these properties based on a Deed of Donation executed in his favor by Angeles Engao, asserting rights over the properties after the death of Romana in 1975.
Conflict and Allegations
- Rosello alleged that following Romana's death, Angeles owned a three-fourths portion of the properties, and the remaining one-fourth belonged to Felipe.
- The controversy arose when Rosello discovered that new titles had been issued in favor of the petitioners, leading him to file a complaint for nullity of documents.
- The petitioners countered, asserting that Rosello was not a legitimate heir and that the documents he cited were invalid due to alleged forgery.
Proceedings in Regional Trial Court
- The RTC initially limited the issues to be resolved, including the ownership of th