Case Summary (G.R. No. 73733)
Background of the Case
The initial civil case (Civil Case No. 727) was instituted by the private respondents, claiming to be the children of Martin Lacerna and Eustaquia Pichan, to acquire their mother's rightful share of the land, which amounted to one-half of the total property. Martin Lacerna contested the claims, denying marriage to Eustaquia and asserting that some of the plaintiffs were not his children. However, the Trial Court ruled in favor of the plaintiffs, determining that Martin was indeed married to Eustaquia and declared the plaintiffs entitled to their share of the property.
Development of Legal Proceedings
Following this ruling, Martin Lacerna appealed to the Intermediate Appellate Court, which upheld the Trial Court's decisions. While the appeal was pending, it was revealed that the Original Certificate of Title No. P-11568 was issued in November 1978 in the name of Martin Lacerna, stating he was married to Epifania Magallon. This certificate was pertinent to the partition case, and its issuance became a focal point in the litigation.
The Writ of Execution
On November 26, 1985, the Trial Court issued an alias writ of execution commanding Martin Lacerna to partition the land in accordance with the judgment. The writ was also served on Epifania Magallon, who subsequently filed a "Motion for Intervention and to Stay Execution," asserting that the land was conjugal property between her and Martin. The Trial Court denied her motion, prompting the filing of the present petition.
The Constructive Trust Doctrine
In deciding the matter, the Court addressed the issue of constructive trusts as outlined in the Civil Code. It established that property obtained through mistake or fraud entrusts the holder as a trustee for the rightful owner. The Court reiterated established principles that when property, through mistake or other unjust means, is registered in the name of a party who has no legitimate claim to it, equity dictates that such a title reflects a constructive trust in favor of the rightful owner.
Legal Status of Petitioner
The Court scrutinized Petitioner Magallon's legal standing and relationship with Martin Lacerna. It acknowledged that while she claimed marital status, there was no formal marriage contract submitted to substantiate her status as a lawful wife. The judgment against Martin Lacerna regarding the partition nevertheless binds her, presuming that she had knowledge of the litigation concerning the land since the inception of the case.
Final Judgment and Directions
The Court determined that t
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Case Overview
- The case concerns a petition by Epifania Magallon seeking to annul a writ of execution issued by Hon. Rosalina L. Montejo, Presiding Judge of the Regional Trial Court of Davao del Sur.
- The underlying case (Civil Case No. 727) involved a partition of land located in Barrio Kasuga, Municipality of Magsaysay, Davao del Sur, claimed by the plaintiffs as heirs of Martin Lacerna and Eustaquia Pichan.
- The plaintiffs, asserting their rights as children of Martin Lacerna and Eustaquia Pichan, sought one-half of the land as Eustaquia's share in their conjugal partnership.
Background of the Case
- Martin Lacerna, the defendant, denied being married to Eustaquia Pichan, asserting they lived together without marriage and that two of the plaintiffs were not his biological children.
- The Trial Court found substantial evidence confirming Martin's marriage to Eustaquia and acknowledged the plaintiffs as his legitimate children.
- The Trial Court awarded the plaintiffs one-half of the homestead land that Martin had worked during his marriage to Eustaquia.
Appeal and Title Issues
- Martin Lacerna appealed the Trial Court's decision to the Intermediate Appellate Court, which affirmed the decision on August 31, 1984.
- At the time of filing the case, no certificate of title had been issued to Martin, but one was eventually issued on November 22, 1978, reflecting him as married to Epifania Magallon, the petitioner in this case.
- The title's issuance w