Chung vs Mondragon
GR No. 179754 November 21, 2012
Facts: Petitioners Joaquin G. Chung, Jr., Paz Royeras-Soler, and Mansueto Maceda are descendants of Rafael Mondragon (Rafael) by his first wife, Eleuteria Calunia (Eleuteria), while respondent Jack Daniel Mondragon (Jack Daniel) is Rafael’s descendant by his second wife, Andrea Baldos (Andrea). Original Certificate of Title (OCT) No. 224476 is registered in the name of “Heirs of Andrea Baldos represented by Teofila G. Maceda” and covers 16,177 square meters of land in Macrohon, Southern Leyte (the land). Petitioners claim that from 1921 up to 2000, Rafael appeared as owner of the land in its tax declaration, and that a free patent was issued in 1987 in the name of Andrea’s heirs upon application of Teofila G. Maceda (Teofila), who is petitioners’ sister. On the other hand, respondents claim that Andrea is the exclusive owner of the land, having inherited the same from her father Blas Baldos. It was alleged that respondent Jack Daniel disposed an undivided portion of the subject parcel of land whereby it was questioned before the trial court whether he has authority to do so to which a favorable judgement was rendered for the former:
After trial, the court a quo rendered its May 19, 2003 Decision dismissing the case. It held that with the admission that Jack Daniel is an heir of Andrea, he being the latter’s grandson and therefore her heir, he is thus a co-owner of the land which forms part of Andrea’s estate, and thus possesses the right to dispose of his undivided share therein. The trial court held that petitioners’ remedy was to seek partition of the land in order to obtain title to determinate portions thereof.
Issues: Whether or not the trial court in rendering its decision violated the constitutional mandate under Art VIII section 14.
Whether or not respondent is entitled to the relief granted by the court.
Held: No. The constitutional requirement that every decision must state distinctly and clearly the factual and legal bases therefor should indeed be the primordial concern of courts and judges. Be that as it may, there should not be a mechanical reliance on this constitutional provision. The courts and judges should be allowed to synthesize and to simplify their decisions considering that at present, courts are harassed by crowded dockets and time constraints. Thus, the Court held in Del Mundo v. Court of Appeals:
It is understandable that courts with heavy dockets and time constraints, often find themselves with little to spare in the preparation of decisions to the extent most desirable. We have thus pointed out that judges might learn to synthesize and to simplify their pronouncements. Nevertheless, concisely written such as they may be, decisions must still distinctly and clearly express at least in minimum essence its factual and legal bases.
The Court finds in this case no breach of the constitutional mandate that decisions must express clearly and distinctly the facts and the law on which they are based. The trial court’s Decision is complete, clear, and concise. Petitioners should be reminded that in making their indictment that the trial court’s Decision fails to express clearly and distinctly the facts and the law on which it is based, they should not mistake brevity for levity.
Yes. The issues in a case for quieting of title are fairly simple; the plaintiff need to prove only two things, namely: “(1) the plaintiff or complainant has a legal or an equitable title to or interest in the real property subject of the action; and (2) that the deed, claim, encumbrance or proceeding claimed to be casting a cloud on his title must be shown to be in fact invalid or inoperative despite its prima facie appearance of validity or legal efficacy. Stated differently, the plaintiff must show that he has a legal or at least an equitable title over the real property in dispute, and that some deed or proceeding beclouds its validity or efficacy.”
It is evident from the title that the land belongs to no other than the heirs of Andrea Baldos, Rafael’s second wife. The land could not have belonged to Rafael, because he is not even named in OCT No. 22447. With greater reason may it be said that the land could not belong to petitioners, who are Rafael’s children by his first wife Eleuteria. Unless Eleuteria and Andrea were related by blood – such fact is not borne out by the record – they could not be heirs to each other. And if indeed Eleuteria and Andrea were blood relatives, then petitioners would have so revealed at the very first opportunity. Moreover, the fact that Rafael died ahead of Andrea, and that he is not even named in the title, give the impression that the land belonged solely to the heirs of Andrea, to the exclusion of Rafael. If this were not true, then the title should have as registered owners the “Heirs of Rafael and Andrea Mondragon”, in which case the petitioners certainly would possess equitable title, they being descendants-heirs of Rafael. Yet OCT No. 22447 is not so written.
Black n white 