Case Summary (G.R. No. 2298)
Applicable Law
This case is governed by the legal principles outlined in the Philippine Civil Code and the Land Registration Act, particularly concerning good faith purchasers and the rights of co-heirs. Given the decision of the case is from 1949, it is based upon the 1935 Philippine Constitution.
Factual Background
The parcel of land, registered under Original Certificate of Title No. 4905, consists of approximately 7.0652 hectares and was acquired as a homestead by Casimiro Evangelista on January 23, 1935. Casimiro was married to Leonida Mari, and they had two children: Caridad and Deogracias Evangelista. Casimiro died intestate in 1938, and shortly thereafter, Deogracias claimed to be the sole heir. On January 10, 1944, he executed a declaration of heirship and sold the property to the defendants for P2,400.
Plaintiffs’ Claim and Defendants’ Defense
The plaintiffs contend that Deogracias Evangelista, not being the registered owner but merely a co-heir, had no right to sell the property without the consent of his co-heirs. The defendants, on the other hand, argue that they purchased the land in good faith, believing Deogracias was legally entitled to sell it based on the certificate of title.
Good Faith Purchase Analysis
One of the primary issues in this case is the protection extended to good faith purchasers under the Land Registration Law. The court highlighted the distinction that good faith protection applies only to actual registered owners. Since the land remained registered in the name of the deceased Casimiro Evangelista, Deogracias' lack of ownership nullified the defendants' claims of having acted in good faith.
Warning to Defendants
The court noted that the circumstances surrounding the sale should have put the defendants on notice to investigate further. The defendants were aware that Deogracias was not the only heir and that there could be claims against the property. Any reliance on the probate proceedings or declarations made by Deogracias was insufficient to protect them, as the judicial partition in probate could not preclude claims from co-heirs not participating in those proceedings.
Judicial Partition Limitations
The ruling emphasized that judicial partitions are not conclusive for heirs who were not parties in such proceedings. This underscores that a partition does not legally diminish ano
...continue readingCase Syllabus (G.R. No. 2298)
Case Overview
- The case revolves around a dispute concerning the ownership of a parcel of land sold by Deogracias Evangelista, the plaintiffs' co-owner, to the defendants.
- Plaintiffs Leonida Mari and Caridad Evangelista seek to recover their combined 3/4 share in the property in question.
Facts of the Case
- Casimiro Evangelista was the registered owner of a homestead parcel of land in Nueva Ecija, holding Original Certificate of Title No. 4905.
- Casimiro was married to Leonida Mari on February 7, 1920, and they had two children, Caridad and Deogracias Evangelista.
- Casimiro died intestate around 1938, leaving behind the aforementioned property acquired on January 23, 1935.
- On January 10, 1944, Deogracias Evangelista executed a declaration of heirship claiming to be the sole heir of Casimiro and sold the property to defendants Isaac Bonilla and Silvina Ordanez for P2,400.
- Following the sale, the original title was cancelled, and a new title (Transfer Certificate of Title No. 19991) was issued in the names of the defendants.
- The defendants took possession of the land and cultivated it, producing crops during the 1944-1945 harvest.
- The plaintiffs, Leonida and Caridad, have resid