Title
Ramiro vs. Reyes
Case
G.R. No. 32296
Decision Date
Mar 31, 1930
Consolidated appeals over disputed land parcels in San Pablo, Laguna; ownership affirmed to Estanislao Reyes via public auction, invalidating claims by others due to *res judicata* and estoppel.
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Case Summary (G.R. No. 32296)

Estoppel and Its Scope

  • The court's declaration of estoppel in the case of Martinez vs. Grao extends to the successors of one of the Martinez heirs.
  • A defendant's ignorance of their rights does not create estoppel against them; such ignorance only ceases when a decision is rendered in a related case.

Judicial Auction and Publication Objections

  • Objections regarding insufficient publication prior to a judicial auction cannot be raised at this stage if not previously addressed in the lower court.
  • Such objections do not affect the court's jurisdiction.

Ownership and Eviction Warranty

  • Warranty for eviction applies when eviction occurs, as per Article 1478 of the Civil Code.

Joint Adjudication of Related Cases

  • The cases involve four parcels of land in San Lorenzo, Laguna, claimed by multiple parties, including Mateo Ramiro, Juana Villanueva, Estanislao Reyes, and Jose Martinez.
  • The Court of First Instance of Laguna ruled that Estanislao Reyes is the rightful owner of the properties in question, ordering others to refrain from disturbing his possession.

Errors Assigned by Appellants

  • Clemencia Grao and Jose Martinez assigned errors regarding the ownership of the parcels and the validity of the auction.
  • Mariano Cabanos raised errors concerning the sale of property and the estoppel of intervenors.
  • Mateo Ramiro and Juana Villanueva also assigned errors related to ownership claims and the application of res judicata.

Acquisition of Property by Estanislao Reyes

  • Estanislao Reyes acquired the disputed parcels through a valid auction following a judgment against Clemencia Grao.
  • The court previously ruled that Reyes holds valid title to the properties, and the appellants' claims are barred by estoppel.

Claims of Jose Martinez and Mariano Cabanos

  • Jose Martinez's claims to certain lots are invalidated by the court's prior ruling on estoppel.
  • Mariano Cabanos's claim to lot 30 is also affected by the estoppel ruling against his predecessor, Jose Martinez.

Appellant Spouses' Claims and Ownership

  • The appellant spouses claim ownership of several parcels but their claims are undermined by prior adjudications favoring Estanislao Reyes.
  • The court found that the spouses purchased land from parties who did not have valid title, thus their claims are invalid.

Parcel B and Pending Litigation

  • Parcel B is claimed by Isidro Martinez, and the court de...continue reading

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