Esquejo v. Fortaleza
REITERATIONFacts
The Antecedents: Aurea Esquejo filed an action to recover a residential land in Sta. Maria, Binalonan, Pangasinan. She claimed the land was donated to her by Pablo Fortaleza as a marriage consideration for her union with his son, Cresenciano. The trial court found that the land was indeed donated but denied recovery because the donor, Pablo Fortaleza, did not own the land. The residential land in question was registered property of Pedro Fortaleza, evidenced by Original Certificate of Title No. 4322. Cerapio Fortaleza, one of the defendants, acquired the land from the heirs of Pedro Fortaleza via a deed of sale (Exh. "2"). Procedural History: The case was filed in the Court of First Instance of Pangasinan. The plaintiff, Aurea Esquejo, appealed the decision directly to the Supreme Court, stating that only questions of law would be raised. The Appeal: Aurea Esquejo appealed the trial court's decision, contending that the donated lot was different from the one covered by Original Certificate of Title No. 4322. She argued that Pablo Fortaleza first donated the residential lot to her and then conveyed the same property to Cerapio Fortaleza via a deed of sale (Exh. "F"). She further alleged that Cerapio Fortaleza later procured another deed of sale (Exh. "2") which was simulated and referred to a different, registered land, while the land she received was unregistered and formerly belonged to Pablo Fortaleza. Her appeal to the Supreme Court was based on questions of law.
Issue(s)
Whether the appellant, by appealing directly to the Supreme Court on questions of law, waived her right to dispute the factual findings of the lower court. Whether the residential land donated to the appellant by Pablo Fortaleza is the same land covered by Original Certificate of Title No. 4322 and subsequently sold to Cerapio Fortaleza. Whether Pablo Fortaleza had the legal right to donate the residential land to the appellant.
Ruling
The Supreme Court affirmed the decision of the lower court. It held that the appellant waived questions of fact by appealing directly to the Supreme Court on questions of law. The Court found that the evidence supported the trial court's conclusion that the donated land was the same registered land owned by Pedro Fortaleza and sold to Cerapio Fortaleza. Since Pablo Fortaleza did not own the land, he could not have validly donated it.
Ratio Decidendi
On Issue 1: The Supreme Court held that the appellant, Aurea Esquejo, waived all questions of fact by filing an appeal directly to the Supreme Court on the ground that only questions of law would be raised. This is in accordance with Rule 42, Section 2 of the Revised Rules of Court. Therefore, the factual findings of the lower court, which were supported by evidence, were binding upon the Supreme Court. The appellant could not dispute the trial court's conclusion that the donated residential land was the same land covered by Original Certificate of Title No. 4322. On Issue 2: The Supreme Court agreed with the trial court's finding that the residential land purportedly donated to the appellant and the land covered by Original Certificate of Title No. 4322, which was sold to Cerapio Fortaleza, were the same property. The trial court examined both documents and was convinced of their identity despite minor discrepancies in boundaries, noting that the areas were practically the same. Tax Declaration No. 14362 (Exh. "3") also supported this conclusion. The defendant Cerapio Fortaleza did not dispute the identity of the residential land in question in relation to Lot 700. On Issue 3: The Supreme Court concluded that Pablo Fortaleza had no right, title, or interest in the residential lot (Lot 700) that he purportedly conveyed to the appellant via a deed of donation. This was because the land was the registered property of Pedro Fortaleza, and Pablo Fortaleza failed to adduce any evidence showing how he acquired it from the registered owner. The Court reiterated the legal principle that nobody can dispose of that which does not belong to him. Consequently, the donation made by Pablo Fortaleza was void for lack of title on his part.
Main Doctrine
The Supreme Court reiterated that an appeal directly to the Supreme Court on questions of law constitutes a waiver of all questions of fact. Moreover, the Court affirmed the principle that a transfer of property is void if the transferor does not possess title to the property, emphasizing the importance of established ownership and registered titles.