GR L 29695; (February, 1987) (Digest)
G.R. No. L-29695 February 27, 1987
LEONA CORPUS and ILADIA CORPUS, plaintiffs-appellees, vs. JACINTA CORPUS and PEDRO ADUCA, defendants-appellants.
FACTS
Plaintiffs-appellees Leona Corpus and Iladia Corpus filed an action for recovery of possession and damages against defendants-appellants Jacinta Corpus and Pedro Aduca over a parcel of land registered under TCT No. 49663 in the name of “Heirs of Domingo Corpus.” The plaintiffs alleged they were the sole legal heirs of the deceased spouses Domingo Corpus and Clara Sibayan, the original owners. They contended that Jacinta, an illegitimate child of Domingo born to a married woman, had no right to inherit. The defendants, however, claimed ownership by virtue of a “Deed of Reconveyance and Confirmation” executed by the former registered owner, Doroteo Cresencia, in 1964, purporting to sell the land to the “Heirs of Domingo Corpus” represented by Pedro Aduca. During pre-trial, the defendants’ counsel moved for postponement, which the trial court denied due to lack of proper notice and the case’s prolonged pendency. The court then allowed the plaintiffs to present evidence ex-parte. The defendants received the order denying their motion but did not move for reconsideration. Subsequently, the trial court rendered a decision in favor of the plaintiffs.
ISSUE
The primary issue is whether the trial court erred in denying the motion for postponement and proceeding with an ex-parte hearing. The secondary issue involves the determination of ownership based on the interpretation of the “Deed of Reconveyance and Confirmation.”
RULING
The Supreme Court affirmed the trial court’s decision. On the procedural issue, the denial of the motion for postponement was proper. The defendants failed to comply with the rules on notice to the opposing party. Moreover, their subsequent inaction—failing to seek reconsideration of the order or to appear at subsequent hearings—constituted a waiver of their right to participate. The trial court did not abuse its discretion in proceeding ex-parte to avoid further delay.
On the substantive issue, the Court examined the “Deed of Reconveyance and Confirmation.” The document explicitly states it is a reconveyance, not an absolute sale, transferring the property to the “Heirs of Domingo Corpus” because Doroteo Cresencia had merely acted as a trustee. Pedro Aduca signed only as a representative of these heirs. Therefore, the deed did not vest ownership in the defendants personally but in the collective heirs of Domingo Corpus. Since Jacinta Corpus, as an illegitimate child of a married woman, was not a legal heir, she could not inherit from Domingo Corpus. Consequently, the plaintiffs, as the only legitimate heirs, are the exclusive owners entitled to possession. The defendants’ claim of purchase was unfounded, as the deed’s terms clearly established a trust and reconveyance in favor of the lawful heirs.
