CAÑETE, Christy Mae, B.
/ Obligations and Contracts June 01, 2023
Bautista v. Bautista
(G.R. No. 202088, March 08, 2017)
Facts:
The Bautista siblings, including Margarito, Manuel, Carmelita, Aniano, Florencia, and
Ester, established a lending business using the proceeds from the sale of a coconut land
they inherited. Through the business, they acquired several properties. One such property
was the Sta. Monica property, which was mortgaged by Amelia Mendoza and later sold
to Margarito. Disputes arose among the siblings, leading to a Complaint for Partition and
Accounting filed by the petitioners against Margarito and others. The Regional Trial Court
(RTC) ruled in favor of the petitioners, declaring the Sta. Monica property as co-owned
by the siblings. Margarito appealed to the Court of Appeals (CA), which reversed the
RTC's decision.
Issues:
Whether the CA erred in entertaining an appealed decision of the RTC that was already
final and executory.
Whether Margarito exclusively owns the Sta. Monica Property by using his personal funds
to purchase it.
Ruling:
The Supreme Court held that the petition had merit. The jurisdiction of the Court in cases
from the CA is limited to reviewing errors of law. However, the arguments raised in this
case required re-evaluation of submissions and factual findings. The RTC's decision was
not yet final and executory when Margarito filed a motion for reconsideration, and the
procedural requirements were substantially complied with.
Regarding the ownership of the Sta. Monica property, the Court found that the evidence
presented by the petitioners established their co-ownership. They provided mortgage
contracts, bank transactions, and a blank Kasulatan to support their claim. Testimonies
showed how the properties were acquired through the lending business and transferred
to their names. Margarito failed to prove exclusive ownership, as he did not present the
deed of sale and relied mainly on the title, tax declarations, and mortgage contracts. The
Court found an implied resulting trust among the siblings, as their intentions and business
practices indicated co-ownership. Thus, the RTC's order of partition was reinstated.
Therefore, the Court granted the petition, reversing the CA's decision and reinstating the
RTC's decision in favor of the petitioners.
