Case Summary (G.R. No. L-5238)

Variance Between Pleadings and Proof

• The defendant claimed ownership of the property in question and presented evidence to support this claim.
• The lower court's decision aligned with the defendant's assertion of lawful ownership, but differed in its interpretation of the legal implications of the evidence presented.
• The court concluded that the defendant's exhibits operated independently to convey property rights, rather than being solely dependent on prior donations.
• This divergence in legal conclusions does not constitute a forbidden variance between pleadings and proof, as it does not mislead the plaintiffs.
• The principle that a plaintiff is entitled to relief based on the facts, regardless of the soundness of their theory, applies equally to defendants.

Validity of Conveyances

• A deed that attempts to convey more than what the grantor possesses is void only concerning the excess, while valid for the portion the grantor can convey.
• The case originated in the Court of First Instance of Nueva Vizcaya, where the plaintiffs sought to reclaim land and damages.
• The trial court ruled in favor of the plaintiffs, declaring them the absolute owners of the land, but this decision was reversed by the Court of Appeals.

Background of Property Ownership

• The property in question was originally held by Estefanio Benito, who obtained a homestead patent in 1930.
• Following his death, his widow executed deeds to formalize prior verbal donations made by Estefanio to his brothers, which were initially void due to legal restrictions.
• The widow's actions were deemed to have legal effect, as she had a rightful interest in the property and acted as the administratrix of her deceased husband's estate.

Court of Appeals Findings

• The Court of Appeals found that the widow's deeds were valid and effectively conveyed property rights, despite the initial illegality of the verbal donations.
• The court noted that the widow's half-interest in the property was not impaired by her actions, and her conveyances were legally sound after the prohibition period.
• The court emphasized that the plaintiffs, as co-owners, could not claim exclusive ownership of the property but were entitled to seek partition instead.

Plaintiffs' Lack of Cause of Action

• The plaintiffs lacked a valid cause of action, as their claim to the property was not supported by the legal framework governing co-ownership.
• Their father's interest in the property remained intact, and they could only seek partition rather than exclusive ownershi...continue reading

Case Syllabus (G.R. No. L-5238)

Case Background

• The case originated in the Court of First Instance of Nueva Vizcaya, where petitioners Margarita and Juliana Benito sought to recover a tract of land and damages from respondent Samuel Enero.
• The trial court ruled in favor of the petitioners, declaring them as absolute owners of the land, and ordered the return of the land by the defendant.
• The decision was appealed, and the 5th Division of the Court of Appeals reversed the trial court’s judgment, leading to the current review.

Factual Background

• Estefanio Benito, father of the petitioners, held a homestead patent issued on August 8, 1930, covering approximately three hectares situated in barrio La Torre, Bayombong, Nueva Vizcaya.
• The property was conjugal, shared with his wife, Apolonia Corpuz, and was identified as Cadastral Lot No. 1108.
• Estefanio Benito passed away in 1934. Shortly before his death, he verbally donated portions of the lot to his brothers, Saturnino and Eugenio Benito, which were later found to be void due to lack of proper documentation and timing.
• On November 3, 1935, Apolonia Corpuz formalized these donations through notarized deeds, Exhibits 3 and 5, which acknowledged the earlier verbal donations and transferred ownership to Saturnino and Eugenio.

Legal Developments

• Saturnino and Eugenio later sold their respective holdings to Toribia Castriciones in 1935 and 1936, who subsequently donated the land to Sa...continue reading