Title
Banguis-Tambuyat vs. Balcom-Tambuyat
Case
G.R. No. 202805
Decision Date
Mar 23, 2015
Adriano's property title erroneously listed Rosario as spouse; Wenifreda, lawful wife, sought correction. Court ruled in Wenifreda's favor, denying Rosario's ownership claims.
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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

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