Case Summary (G.R. No. L-15743)
Initial Proceedings
Ombe filed her verified petition for the cancellation of Vicente Diga’s acknowledgment of marriage inscribed in the title to the land in question, seeking to have her status reflected as "single." While the petition was pending, Diga allegedly harvested crops from the land, prompting Ombe to file a separate action for injunction against him on July 28, 1956. The court issued a writ of preliminary injunction on July 31, 1956, prohibiting Diga from entering the property or harvesting any products until the case was resolved.
Defendant’s Claims
In response, Vicente Diga contended that he and Ombe were married according to Bagobo customs and that he had supported Ombe and her children since 1946. He counterclaimed against Ombe for P2,000.00, citing expenses incurred due to the lawsuit and requested a share of the property. The case became complicated with a stipulated agreement regarding the facts, including the nature of their relationship and Ombe's prior claims to ownership of the land.
Stipulated Facts and Court's Initial Decision
The stipulation of facts submitted by both parties revealed that Ombe had occupied and cultivated the land since 1928 and had also filed for a free patent before the outbreak of World War II, although the documentation of this application was lost. The trial court concluded that the land belonged to both parties due to their cohabitation, aligning its decision with Articles 144 and 486 of the New Civil Code of 1950.
Appellate Proceedings and Legal Reasoning
Upon appeal, Ombe contested the trial court's ruling, arguing that the lower court had erred in dismissing her complaint and awarding joint ownership of the land. The Supreme Court highlighted that, based on the stipulated facts, Ombe maintained continuous and public possession of the land for years, which allowed her to acquire a perfect title through a free patent granted post-war.
Legal Framework and Conclusion
The review of previous jurisprudence
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Case Background
- On June 2, 1956, plaintiff Ombe (Bagoba) filed a verified petition with the Court of First Instance of Davao for the cancellation of Original Certificate of Title No. P-1108.
- The title in question covered a parcel of land located in barrio Baracatan, Sta. Cruz, Davao, with an area of approximately 121,761 square meters.
- The plaintiff sought to replace the words "married to Vicente Diga" with her true marital status of "single."
- While the petition was pending, Vicente Diga allegedly harvested crops from the land without the plaintiff's consent.
Preliminary Injunction
- On July 28, 1956, the plaintiff filed a separate action for injunction against Diga, requesting a preliminary injunction.
- The Court issued an ex parte writ of preliminary injunction on July 31, 1956, prohibiting Diga and his associates from entering the land or harvesting crops pending the litigation.
Defendant's Response
- Vicente Diga filed his answer on August 10, 1956, claiming that he and the plaintiff had been living as common-law partners since 1946.
- Diga asserted that he had supported the plaintiff and her children and denied that he acted against her will in harvesting crops.
- He also counterclaimed for P2,000.00 in expenses incurred from the lawsuit and requested a share of the property.
Stipulation of Facts
- On February 6, 1957, both parties