G.R. No. L-11572; March 30, 1962
ROMAN SANTOS, plaintiff-appellee, vs. FRANCISCO C. BAYLON, defendant-appellant.

FACTS

Roman Santos filed a complaint against Francisco C. Baylon seeking the annulment of a deed of donation inter-vivos executed by Rosa de los Reyes in favor of Baylon, who was her husband. Santos claimed to be the sole legal heir of Rosa and sought to recover ownership and possession of the donated properties. The trial court rendered a mixed judgment. It declared the deed of donation null and void. However, it also ruled that Santos could not inherit from Rosa ab-intestato because he was not her legitimate brother. Consequently, the court dismissed Santos’s complaint and declared Baylon, as the surviving spouse, the rightful owner of the properties by right of inheritance.
Both parties appealed the decision. Defendant Francisco Baylon appealed directly to the Supreme Court, but limited his appeal solely to assailing that portion of the judgment which declared the deed of donation null and void. Plaintiff Roman Santos, on the other hand, appealed to the Court of Appeals, raising pivotal questions of fact, primarily concerning whether his parents were lawfully married to determine if he was indeed the legitimate brother of Rosa de los Reyes and thus a legal heir.

ISSUE

The core procedural issue is whether the Supreme Court should retain jurisdiction over Baylon’s appeal, which he frames as purely legal, or refer it to the Court of Appeals in light of the interrelated factual issues raised in Santos’s separate appeal.

RULING

The Supreme Court ruled to refer Baylon’s appeal to the Court of Appeals. The legal logic is grounded on jurisdiction and judicial economy. While Baylon’s appeal ostensibly involves only the legal validity of the donation, the case as a whole presents mixed questions of law and fact. The Court emphasized that when an appeal fairly involves both questions of law and fact, jurisdiction lies with the Court of Appeals, not the Supreme Court.
Crucially, the factual determinations to be made by the Court of Appeals in Santos’s appeal could directly affect or even render moot the legal issue raised by Baylon. For instance, if the Court of Appeals finds that Santos is not a legitimate heir, Baylon would be declared the owner by inheritance regardless of the donation’s validity, as the trial court initially held. To avoid the potential for inconsistent rulings between two courts on intimately related issues arising from the same case, the Supreme Court deemed it imperative to consolidate the appeals. Therefore, the entire case, including Baylon’s appeal on the legal question, was referred to the Court of Appeals for proper and unified disposition.