Case Summary (G.R. No. 161030)
Procedural Background
This case originated from a petition for review on certiorari under Rule 45 of the 1997 Rules of Civil Procedure to reverse the November 24, 2003 Decision of the Court of Appeals, which overturned the May 16, 2002 Decision by the Regional Trial Court (RTC) of Malolos, Bulacan in Civil Case No. 256-M-97. In the lower court's decision, an order for partition of the property among the heirs was granted.
Nature of the Property and Initial Claims
The property is registered in the names of Jose A. Fernando (married to Lucila Tinio) and Antonia A. Fernando (married to Felipe Galvez). Upon their deaths intestate, the property remained undivided, leading to a conflict among the heirs regarding its partition. The petitioners claimed their rightful shares, while the respondents raised counterclaims based on past judgments regarding the property's subdivision into lots.
Respondents’ Counterclaims and Intervention
Respondent Leon Acuna presented a complaint in intervention, claiming that part of Lot 1303 had been previously adjudicated to multiple persons in 1929. He asserted that some portions had been sold and contested the petitioners' claims based on previous court decisions. Similarly, Hermogenes Fernando intervened, claiming that lots had already been adjudicated to their predecessors and arguing that the present action was barred by res judicata.
Trial Court Ruling
The trial court found that the parties were indeed the descendants of the original owners and noted that Lot 1302 had been fully allocated, which affected the partition of Lot 1303. The court determined that the 1929 Decision had not been properly executed, allowing the petitioners to reclaim Lot 1303. However, the court ruled against the petitioners regarding Sapang Bayan, concluding that the issue had not been adequately raised during pre-trial.
Court of Appeals Decision
The Court of Appeals reversed the RTC's decision, holding that the lower court erred in its determination of ownership and partition. It concluded that the rights to Lot 1303 and Sapang Bayan had been adjudicated in earlier proceedings and affirmed the respondents’ ownership claims.
Supreme Court’s Analysis on Lot 1303
The Supreme Court agreed with the appellate court regarding the ownership of Lot 1303, confirming that it had been divided and allocated among several claimants per the 1929 Decision. The justices noted that the registered title—which was claimed by petitioners—had long been subject to the 1929 decision that had given portions to other individuals, and as such, the petitioners could not claim ownership
...continue readingCase Syllabus (G.R. No. 161030)
Case Background
- This case involves a petition for review on certiorari under Rule 45 of the 1997 Rules of Civil Procedure to reverse the Court of Appeals' decision dated November 24, 2003.
- The controversy revolves around a parcel of land covered by Original Certificate of Title (OCT) No. RO-487 (997), registered in the names of Jose A. Fernando and Antonia A. Fernando, located in San Jose, Baliuag, Bulacan.
- Upon the death of the registered owners, the property remained undivided, prompting the petitioners, who are the heirs, to seek partition of the property.
Parties Involved
- Petitioners: Jose Fernando, Jr., Zoilo Fernando, Norma Fernando Banares, Rosario Fernando Tangkencgo, and various heirs of the deceased owners.
- Respondents: Leon Acuna, Hermogenes Fernando, and the heirs of spouses Antonio Fernando and Felisa Camacho.
Procedural History
- Petitioners filed a complaint for partition against the heirs of Germogena Fernando on April 17, 1997, after failing to reach an agreement on property division.
- The defendants admitted the allegations in the complaint and expressed willingness to share expenses during proceedings.
- Respondent Leon Acuna filed a complaint in intervention, claiming prior adjudication of portions of the property in earlier court decisions.
Key Issues Raised
- Whether the ownership of Lot 1303 and Sapang Bayan should revert to the descendants of the original owners.
- Whether a title registered under the Torrens system serves