Del Castillo v. Del Castillo
REITERATIONFacts
The Antecedents: Miguel del Castillo and his siblings, Pablo, Flaviano, Jacinto, Anunciacion, and Agatona, were co-owners of a parcel of land. Miguel, Pablo, and Flaviano filed an action for partition and damages against Jacinto, Anunciacion, Agatona, and the vendees of Anunciacion's and Flaviano's shares. They sought to annul a deed of donation dated April 10, 1958, in favor of Anunciacion, and a Deed of Extra-judicial Partition dated June 11, 1962. They also prayed for Miguel's declaration as co-heir, partition of the property, and damages. Procedural History: The Court of First Instance of Cebu rendered judgment declaring the parties co-owners and adjudicating specific sub-lots to each. It declared the deed of donation and the deed of extra-judicial partition valid insofar as they did not encroach on the assigned portions. It dismissed mutual claims for damages. Only Flaviano del Castillo appealed to the Court of Appeals. The Court of Appeals modified the trial court's judgment, declaring the deed of extra-judicial partition null and void in part concerning Lot No. 179-F, and awarding it to Miguel del Castillo, minus the 85 square meters he donated to Anunciacion. Anunciacion's motions for reconsideration were denied. The Petition: Anunciacion del Castillo filed a petition for review on certiorari with the Supreme Court, arguing that the Court of Appeals erred in granting affirmative relief to Miguel del Castillo, who had not appealed the trial court's decision.
Issue(s)
Whether the Court of Appeals erred in granting affirmative relief to Miguel del Castillo, an appellee who had not appealed the trial court's decision. Whether the Court of Appeals erred in declaring the deed of donation partially null and void and modifying the adjudication of Lot No. 179-F.
Ruling
The Supreme Court reversed and set aside the Court of Appeals' decision insofar as it nullified the deed of extra-judicial partition concerning Lot No. 179-F and declared Miguel del Castillo entitled to it. The judgment of the trial court adjudicating Lot No. 179-F in its entirety to Anunciacion del Castillo was sustained. The rest of the Court of Appeals' decision, upholding the validity of the deed of extra-judicial partition for other lots, was affirmed.
Ratio Decidendi
On the issue of affirmative relief for an appellee: The Supreme Court reiterated the rule that an appellee who has not himself appealed cannot obtain affirmative relief from the appellate court beyond what was granted in the lower court's decision. Miguel del Castillo did not appeal the trial court's judgment, thus implicitly accepting it. His role in Flaviano's appeal was solely as an appellee. Therefore, he could not seek affirmative relief, and the Court of Appeals had no power to grant him any. The judgment of the trial court had become final and unalterable as to Miguel. On the validity of the deed of donation and adjudication of Lot No. 179-F: The Supreme Court found the Court of Appeals' declaration that only 85 square meters were donated to be erroneous. The deed of donation clearly indicated Miguel's intention to donate the entire parcel of land described within specific boundaries, not merely a portion or 85 square meters. The stated area of "85 square meters, more or less" was an error, which the trial court had also recognized by finding that Anunciacion's share should include a portion donated by Miguel. The appellate court's disregard of these facts and its different finding were unwarranted. The trial court's finding that Anunciacion was entitled to Lot No. 179-F in its entirety, as per the deed of donation and partition, was sustained.
Main Doctrine
An appellee who has not himself appealed cannot obtain from the appellate court any affirmative relief other than what was granted in the decision of the lower court. The judgment of the lower court becomes final and unalterable as to the appellee.