Case Summary (G.R. No. 18058)
Petitioner and Respondent
Petitioner: Fabiola Severino (and intervenor Felicitas Villanueva as administratrix)
Respondent: Guillermo Severino
Key Dates
• 1901 – Possessory information filed on behalf of Melecio; land entered in Mortgage Law Register
• May 25, 1915 – Death of Melecio Severino
• 1916–1917 – Cadastral proceedings and issuance of Torrens certificates to Guillermo
Applicable Law
• Philippine Civil Code of 1902 (art. 130) and Code of Civil Procedure (sec. 334(1)) – Presumption of natural child status
• Land Registration Act (Act No. 496) – Torrens system, indefeasibility (sec. 38), burdens and incidents (sec. 70), equitable remedies (sec. 102)
• Equity principles on fiduciary duty and trust (agent/trustee estoppel)
Factual Background
Melecio owned a continuous 799-hectare tract in Silay, Occidental Negros. From 1902 until Melecio’s death, Guillermo administered and occupied the land. In 1916 cadastral proceedings, Guillermo (through counsel) claimed and secured Torrens titles to four lots aggregating 799 ha, although Fabiola was a minor and not represented.
Procedural History
Fabiola sued to recover four parcels or P800,000 in damages for wrongful registration. Villanueva intervened on behalf of the estate. The trial court recognized Fabiola as Melecio’s natural child and ordered Guillermo to reconvey 428 ha to the estate and remit mortgage proceeds. Guillermo appealed, raising nine assignments of error.
Issues Presented
- Validity of Fabiola’s acknowledgment as natural child
- Area and valuation of Melecio’s land
- Allegations of fraud and breach of fiduciary duty by Guillermo
- Effect of Torrens registration on equitable claims
- Procedural questions on attachment
Trial Court’s Findings
• Fabiola is an acknowledged natural child entitled to inheritance
• Melecio’s estate comprised 428 ha at death
• Land value at P500/ha was reasonable
• Guillermo obtained Torrens titles by fraud and must reconvey
Recognition of Natural Child
Although indispensable heirs were omitted, the appellate court deemed this issue immaterial to Villanueva’s relief. The presumption favoring natural child status under Civil Code art. 130 and CCP sec. 334(1) sufficed, and final probate can settle Fabiola’s status.
Determination of Land Area
Guillermo’s 1913 sworn testimony and 1901 possessory records justified the trial court’s finding of 428 ha, notwithstanding Melecio’s 1906 tax declaration of 324 ha. The discrepancy did not warrant disturbance.
Valuation and Attachment
The court’s P500/ha estimate was within reason; the ex parte preliminary attachment and its refusal to dissolve did not constitute reversible error.
Fiduciary Duty and Equitable Relief
Guillermo held the land as Melecio’s agent and cestui que trust. Under well-established equity and comparative jurisprudence, an agent who acquires legal title for himself is equitably bound to reconvey to the principal. Fraud need not be separately proved to invoke trustee estoppel.
Effect of Torrens Registration
The action is in
Case Syllabus (G.R. No. 18058)
Parties and Relief Sought
- Plaintiff – Fabiola Severino, alleged natural daughter and sole heir of the deceased Melecio Severino, seeks conveyance of four parcels of land or payment of ₱800,000 in damages for wrongful registration by defendant.
- Intervenor – Felicitas Villanueva, administratrix of the estate of Melecio Severino, claims the same relief in favor of the estate rather than the plaintiff.
- Defendant – Guillermo Severino, brother of Melecio, named as administrator during Melecio’s lifetime, denies all allegations and appeals the lower court’s judgment.
Land Description and Historical Possession
- The property comprises four contiguous cadastral lots in Silay, Occidental Negros (Nos. 827, 828, 834, 874) totaling 799 ha, 75 a, 46 ca.
- In 1901, Agapito Severino instituted possessory information for 428 ha in Melecio’s name; recorded in the Mortgage Law Register.
- During Melecio’s life, Guillermo administered and cultivated the land; he continued occupation after Melecio’s death (25 May 1915).
- A 1916 parcel survey and cadastral proceedings divided the tract into four numbered lots; no opposition was filed against Guillermo’s claim.
- In March 1917, certificates of title were issued to Guillermo based solely on his attorney’s affidavit of thirty-year possession and inheritance claim.
Procedural History
- Fabiola filed an action to compel conveyance or damages against Guillermo.
- Felicitas intervened as administratrix, seeking identical relief for the estate.
- Guillermo answered both complaints with a general denial.
- The Court of First Instance recognized Fabiola as Melecio’s acknowledged natural child, ordered Guillermo to convey 428 ha to Felicitas, to account for mortgage proceeds, and taxed costs.
- Only the defendant appealed.
Assignments of Error on Appeal
- Attack on evidence and findings recognizing Fabiola as natural child (Errors 1–2).
- Exclusion of defendant’s evidence of lack of fraud (Error 3).
- Finding of fraudulent procurement of title (Error 4).
- Determination of land area at death (Error 5).
- Valuation of land