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Labagala V Santiago CASE DIGEST

The case involved a dispute over ownership of a parcel of land between Labagala and the sisters of Jose Santiago. Jose originally owned the land but his sisters claimed he fraudulently registered it solely in his name. After Jose died intestate, his sisters filed a case to recover the 2/3 portion of the land they claimed to own. Labagala, who claimed to be Jose's daughter, contested this, claiming she inherited Jose's 1/3 portion. The Court of Appeals reversed the trial court ruling in favor of Labagala. The Supreme Court affirmed this decision, finding Labagala provided no valid proof she was Jose's daughter and thus could not inherit his portion through intestate succession. It also found the

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3K views2 pages

Labagala V Santiago CASE DIGEST

The case involved a dispute over ownership of a parcel of land between Labagala and the sisters of Jose Santiago. Jose originally owned the land but his sisters claimed he fraudulently registered it solely in his name. After Jose died intestate, his sisters filed a case to recover the 2/3 portion of the land they claimed to own. Labagala, who claimed to be Jose's daughter, contested this, claiming she inherited Jose's 1/3 portion. The Court of Appeals reversed the trial court ruling in favor of Labagala. The Supreme Court affirmed this decision, finding Labagala provided no valid proof she was Jose's daughter and thus could not inherit his portion through intestate succession. It also found the

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© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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G.R. No.

132305

December 4, 2001

LABAGALA vs. SANTIAGO FACTS: Jose T. Santiago owned a parcel of land in Manila. However, his sisters sued him for recovery of 2/3 share of the land alleging that he had fraudulently registered it in his name. The trial court decided in favor of his sisters. Jose died intestate. His sisters then filed a complaint efore the !T" for recovery of the #/3 portion of said property which was in the possession of $da ". %a agala &who claimed to e $da ". Santiago, the daughter of Jose'. The trial court ruled in favor of %a agala. (ccording to the trial court, the said deed constitutes a valid donation. )ven if it were not, petitioner would still e entitled to Jose*s #/3 portion of the property as Jose*s daughter. +hen appealed, the "ourt of (ppeals &"(' reversed the decision of the trial court. $t too, into account that $da was orn of different parents, as indicated her irth certificate. ISSUES: #. +-. respondents may impugn petitioner*s filiation in this action for recovery of title and possession. 2. +-. petitioner is entitled to Jose*s #/3 portion of the property he co/owned with respondents, through succession, sale, or donation. ELD: The "ourt (00$!M)1 the decision of the "(. -n $ssue .o. # 2es. (rticle 233 refers to an action to impugn the legitimacy of a child, to assert and prove that a person is not a man*s child y his wife. However, the present respondents are asserting not merely that petitioner is not a legitimate child of Jose, ut that she is not a child of Jose at all.

( aptismal certificate, a private document, is not conclusive proof of filiation. 4se of a family name certainly does not esta lish pedigree. Thus, she cannot inherit from him through intestate succession. -n $ssue .o. 2 .o. The "ourt ruled that there is no valid sale in this case. Jose did not have the right to transfer ownership of the entire property to petitioner since 2/3 thereof elonged to his sisters. 5etitioner could not have given her consent to the contract, eing a minor at the time. "onsent of the contracting parties is among the essential re6uisites of a contract, including one of sale, a sent which there can e no valid contract. Moreover, petitioner admittedly did not pay any centavo for the property which ma,es the sale void. (rticle #78# of the "ivil "ode provides that if the price is simulated, the sale is void, ut the act may e shown to have een in reality a donation, or some other act or contract. .either may the purported deed of sale e a valid deed of donation. )ven assuming that the deed is genuine, it cannot e a valid donation. $t lac,s the acceptance of the donee re6uired y (rt. 829 of the "ivil "ode. :eing a minor, the acceptance of the donation should have een made y her father or mother or her legal representative pursuant to (rt. 87# of the same "ode. .o one of those mentioned in the law accepted the donation for $da.

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