Case Summary (G.R. No. L-27696)
Procedural History
• May 22, 1964: Joint application filed under Act 496 for registration of the land.
• No opposition except a withdrawn Director of Lands’ protest; order of general default entered.
• Clerk of Court took evidence; trial court issued decision on November 29, 1966 confirming ownership shares.
• Appellees moved to withdraw their shares; denied. Trial court refused to annotate Exhibit O-1 against appellees’ shares and held it void as an unaccepted donation.
• Motion for new trial denied January 14, 1967, but decision modified to acknowledge appellee Sr.’s right to revoke.
• Petitioners-appellants appealed directly pursuant to Rule 41, Rules of Court.
Stipulation at Issue (Exhibit O-1)
“Los productos de esta parcela … se destinan para costear los gastos … procesión del Niño Jesús … construcción de un camarín … Lo que sobra … se repartirá entre los herederos.”
– Fruits of the Lubong parcel were to defray Holy Week and related Church expenses; surplus to be shared among heirs.
Positions of the Parties
• Petitioners-Appellants: Sought annotation of Exhibit O-1 as an encumbrance on all titles.
• Petitioners-Appellees: Argued Exhibit O-1 was void (no acceptance by Church) and, with two of them not parties to the partition, could be revoked; moved to withdraw their shares altogether.
• Petitioners-Appellants contested both the withdrawal motion and the trial court’s jurisdiction to decide Exhibit O-1’s validity in land registration proceedings.
Trial Court’s Disposition
• Confirmed registration and apportioned shares among all applicants.
• Held Exhibit O-1 void as a donation unaccepted by the Church (Art. 745, 748, Civil Code).
• Modified decision to allow annotation only against appellants’ shares, refusing annotation for appellees.
• Denied motions for reconsideration.
Issues on Appeal
- Whether Exhibit O-1 is revocable at the unilateral option of any co-owner.
- Whether Exhibit O-1 binds all signatories and their successors, including appellees.
- Whether a Land Registration Court may pass on the merits of an alleged encumbrance in registration proceedings.
Supreme Court’s Analysis on Revocability
– Exhibit O-1 is part of an extrajudicial partition contract. Under Art. 1308, New Civil Code, contracts bind all parties and cannot be severed at one party’s whim.
– Contracts with stipulations take effect among parties, their heirs and assigns (Art. 1311, New Civil Code).
– A stipulation pour autrui is sustained if it clearly and deliberately benefits a third person.
Stipulation Pour Autrui and Its Requisites
- The stipulation is part (not the whole) of a contract.
- It confers an unconditioned benefit on the third person.
- Neither contracting party acts as agent of the third person.
– Exhibit O-1 meets these criteria: it confers a direct, material benefit on the Church to defray yearly Holy Week expenses.
Supreme Court’s Findings on Acceptance
– Although a stipulation pour autrui requires acceptance by the third party before revocation, no specific formal communication is required.
– The Church’s uninterrupted enjoyment of the land’s fruits from 1941 to 1963 constitutes implied acceptance under Art. 1257, Civil Code.
– Once accepted, the stipulation cannot be revoked unilaterally.
Enforceability Against Privies
– Successive purchasers (Salvador Jr. and Angel Encarnacion) are privies in interest and
Case Syllabus (G.R. No. L-27696)
Facts of the Case
- On May 22, 1964, eight heirs (appellants) and three oppositors (appellees) jointly filed an application under Act 496 to register an agricultural parcel in Barrio Lubong, Dacquel, Cabugao, Ilocos Sur.
- The applicants claimed pro-indiviso fee-simple ownership, no liens or encumbrances, and acquisition by inheritance from their aunt, Dona Encarnacion Florentino, who died in 1941.
- A deed of extrajudicial partition dated August 24, 1947 (Exhibit O) allocated shares and included stipulation Exhibit O-1: fruits of the land to defray specified ecclesiastical expenses, with surplus to be divided among heirs.
- Salvador Encarnacion, Jr. and Angel Encarnacion acquired their shares by purchase from original heirs and Asuncion Florentino.
Lower Court Proceedings
- Publication and hearing notices issued; no oppositions filed except initially by the Director of Lands, later withdrawn—resulting in order of general default.
- Clerk of Court received evidence; Miguel Florentino moved to annotate Exhibit O-1 as an encumbrance on the title.
- Oppositors filed a manifestation to withdraw their shares; appellants opposed.
- On November 17, 1966, the court simplified issues: all parties admitted the fruits arrangement existed, was unregistered, known to them, and partition deed unsigned by Jr. and Angel.
- Decision of November 29, 1966 confirmed registration, awarded undivided shares, but held Exhib