Case Summary (G.R. No. 202805)
Factual Background
- Adriano M. Tambuyat and Wenifreda Balcom-Tambuyat were married on September 16, 1965.
- Adriano acquired a 700-square meter parcel of land in Bulacan on November 17, 1991, with the deed of sale signed solely by him.
- The title was issued in the name of "ADRIANO M. TAMBUYAT married to ROSARIO E. BANGUIS," despite Rosario Banguis-Tambuyat being married to Eduardo Nolasco since October 15, 1975.
- Adriano died intestate on June 7, 1998, leading Wenifreda to file a petition for cancellation of the title on October 18, 1999.
Petition for Cancellation
- Wenifreda's petition claimed she was Adriano's surviving spouse and that the title was erroneously registered.
- She alleged that Banguis was still married to Nolasco and could not be Adriano's spouse.
- Wenifreda sought the cancellation of the title, issuance of a new title in her name, and damages.
- Banguis opposed the petition, asserting she purchased the property with her own funds and that the trial court lacked jurisdiction.
Evidence Presented
- Evidence included marriage contracts, social security records, and testimonies regarding the relationships and ownership of the property.
- Banguis claimed she was married to Adriano and had a child with him, while also acknowledging her marriage to Nolasco.
- The trial court considered various documents, including a negative certification of marriage between Banguis and Adriano.
Trial Court Decision
- The Malolos RTC ruled in favor of Wenifreda, ordering the cancellation of the title and awarding damages to her.
- The court found that Wenifreda was the lawful spouse of Adriano and that the title was erroneously issued.
- Banguis's counterclaim was dismissed for lack of merit.
Court of Appeals Ruling
- Banguis appealed the RTC decision, arguing jurisdictional issues and the need for a separate proceeding.
- The CA affirmed the RTC's decision but modified the award of damages, stating that the trial court correctly applied Section 108 of PD 1529.
- The CA found that Banguis's claims of ownership were not substantiated and that she had acquiesced to the trial court's jurisdiction.
Issues Raised by Petitioner
- Banguis contended that the CA erred in affirming the RTC's cancellation of the title without proper jurisdiction.
- She argued that the trial court disregarded her proof of ownership and possession of the property.
- Banguis claimed the decision violated Article 148 of the Family Code regarding property sharing in defective marriages.
- She also challenged the immediate execution of the RTC's decision despite her appeal.
Petitioner’s Arguments
- Banguis maintained that the trial court lacked jurisdiction to resolve the contentious issues raised in her opposition.
- She argued that the property was acquired solely with her funds and that she had been in possession of it.
- Banguis asserted that the case involved partitioning Adriano's estate, which should have been addressed in a different court.
Respondent’s Arguments
- Wenifreda countered that the trial court had the authority to resolve the objections raised by Banguis.
- She emphasized that Banguis failed to prove her ownership of the property and that the deed of sale indicated Adriano as the sole vendee.
- Wenifreda noted that Banguis had the opportunity to participate in the proceedings regarding the writ of execution but chose not to.
Court's Ruling
- The Court denied Banguis's petition, affirming the CA's decision.
- It held ...continue reading
Case Syllabus (G.R. No. 202805)
Background of the Case
- This case involves a petition for review on certiorari filed by Rosario Banguis-Tambuyat against Wenifreda Balcom-Tambuyat, challenging the Court of Appeals' decision which affirmed a lower court's ruling.
- The case originated from a dispute concerning the ownership of a parcel of land acquired during the marriage of Adriano M. Tambuyat and Wenifreda Balcom-Tambuyat.
Factual Antecedents
- Adriano M. Tambuyat and Wenifreda Balcom-Tambuyat were married on September 16, 1965. During their marriage, Adriano acquired several properties, including a 700-square meter lot in Bulacan.
- The property was acquired on November 17, 1991, with the deed of sale signed solely by Adriano. Rosario Banguis, the petitioner, was a witness to this deed.
- The property was registered under "ADRIANO M. TAMBUYAT married to ROSARIO E. BANGUIS," although Banguis was legally married to another man, Eduardo Nolasco, at the time.
- Adriano passed away intestate on June 7, 1998. Wenifreda filed a petition for cancellation of the title, claiming to be Adriano's surviving spouse.
Legal Proceedings
- Wenifreda's petition alleged that the title was erroneously issued and requested a new title be issued in her name as Adriano's lawful spouse.
- Banguis opposed the petition, asserting she was the rightful owner of the property and that her marriage to Adriano existed.
- The trial court ruled in favor of Wenifreda, ordering the cancellation of the title and awarding damages to her.
Trial Court's Decision
- The Regional Trial Court (RTC) found that Wenifreda was indeed the lawful spouse of Adriano and that Banguis's name was errone...continue reading