Case Summary (G.R. No. 187850)
Facts
The genesis of the dispute arises from a Deed of Absolute Sale executed by Ambrosia Lelina in favor of her son, Rodolfo Lelina, on April 1, 1975. The Deed specified an area of only 810 square meters, although it described the entire property based on its boundaries. Respondent took possession of this property immediately and conducted activities until late 1995. However, in August 1996, respondent learned that petitioner claimed ownership through a Deed of Final Conveyance following a foreclosure sale. This prompted respondent to file a complaint for quieting of title and cancellation of documents related to the title claimed by petitioner.
Petitioner contends that she acquired the 16,047 square meters of land through a foreclosure auction as a judgment creditor against Aquilino Lelina, Ambrosia's husband. After legally acquiring the property and not redeeming it within a year, she successfully obtained a Deed of Final Conveyance, which was registered with the Register of Deeds.
Issues
The core legal issues include:
- Whether respondent is the owner of one-half of the contested property?
- Whether the cancellation of the Deed of Final Conveyance and corresponding Tax Declaration in petitioner’s name was justified?
Ruling
The petition was denied with the Supreme Court affirming the CA’s decision and the RTC ruling. The factual findings of the RTC, supported by the CA, were considered conclusive and not subject to re-evaluation in this petition.
Respondent's Ownership
The Supreme Court found that the evidence presented by respondent, including the Deed of Absolute Sale, established his ownership of half of the levied property. Despite petitioner’s argument regarding the admissibility of the photocopy of the Deed, the Court noted that her belated objection to its admissibility under the best evidence rule was waived due to a lack of timely rationale at trial. As such, the contents of the Deed and respondent’s continuous possession of the property were sufficient to substantiate his ownership claims.
Deed of Final Conveyance Validity
The Supreme Court upheld the findings that the Deed of Final Conveyance was void because it stemmed from an invalid levy. The Court highlighted that a money judgment can only be enforced on property belonging unequivocally to the judgment debtor. Since the property was proven to have been owned by Ambrosia at the time of the levy (and thereby not liable for Aquilino's debts), any claims to ownership a
...continue readingCase Syllabus (G.R. No. 187850)
Case Overview
- This case involves a petition for review on certiorari filed by Anita U. Lorenzana (petitioner) challenging the decisions of the Court of Appeals (CA) and the Regional Trial Court (RTC).
- The principal issue centers on the ownership of a parcel of land measuring 16,047 square meters, where the RTC ruled in favor of Rodolfo Lelina (respondent), affirming his ownership over half of the property and cancelling the Deed of Final Conveyance and Tax Declaration in the name of the petitioner.
Factual Background
- On April 1, 1975, Ambrosia Lelina executed a Deed of Absolute Sale for one-half of a parcel of land, covered by Tax Declaration No. 14324-C, to her son Rodolfo Lelina, specifying an area of only 810 sq. m.
- The Deed described the property’s boundaries, and respondent took possession immediately after the sale, receiving produce from tenants until December 1995.
- In August 1996, it was revealed to respondent that petitioner claimed ownership of the property based on a Deed of Final Conveyance and Tax Declaration No. 11-21367-A in her name.
- Respondent filed a complaint for quieting of title and cancellation of documents on September 24, 1996, asserting a cloud over his ownership.
- Petitioner claimed ownership through a foreclosure sale after being awarded a judgment in a collection case against Aquilino Lelina (Ambrosia's husband).
Trial Court Proceedings
- Respondent's claim was based on the Deed of Absolute Sale, while petitioner argued her ownership was established through the auction sale of the levied property.
- The RTC determined that the property belonged exclu