Mendoza v. Delos Santos
REITERATIONFacts
The Antecedents: The underlying dispute concerns three parcels of land in Sta. Maria, Bulacan. The petitioners, grandchildren of Placido and Dominga Mendoza, claim these properties originated from their grandparents and were passed down through their uncle Exequiel, then to Exequiel's daughter Gregoria. Upon Gregoria's death without issue, the petitioners assert that the respondent, Julia Delos Santos (sister of Gregoria's mother, Leonor), improperly claimed these properties. The petitioners argue that these properties should have been reserved for them under the principle of reserva troncal, as they are relatives within the third degree of the Mendoza line from which the properties allegedly originated. The respondent disputes this, claiming the properties were purchased by Exequiel and Antonio from a third party and did not originate from Placido and Dominga. Procedural History: The petitioners filed an action for Recovery of Possession by Reserva Troncal, Cancellation of Title, and Reconveyance with the Regional Trial Court (RTC) of Malolos, Bulacan. The RTC ruled in favor of the petitioners, ordering the reconveyance of the properties. On appeal, the Court of Appeals (CA) reversed the RTC's decision, dismissing the petitioners' complaint. The CA found that the petitioners failed to establish that the properties originated from Placido and Dominga and also ruled that the conditions for reserva troncal were not met, specifically regarding the lineal descent and the timing of deaths. The petitioners' motion for reconsideration was denied by the CA. The Petition: The petitioners seek review of the CA's decision through a petition for certiorari under Rule 45 of the Rules of Court. They contend that the CA erred in holding that the subject properties are not reservable and that they do not have a right to the properties by virtue of reserva troncal. The petitioners argue that it is sufficient that the properties came from the paternal line of Gregoria and that they, as children of Gregoria's uncles (Antonio and Valentin), are entitled to the reservation, even if they are fourth-degree relatives, by right of representation. The Supreme Court, however, found that the properties did not originate from the petitioners' ascendants in a manner that would trigger reserva troncal, and that the petitioners, being fourth-degree relatives of Gregoria, are not reservees (reservatarios) under Article 891 of the Civil Code.
Issue(s)
Whether the subject properties are reservable properties under Article 891 of the Civil Code. Whether the petitioners are entitled to the reservation of the subject properties.
Ruling
The petition is denied. The Court affirmed the Court of Appeals' decision dismissing the complaint, holding that the conditions for reserva troncal were not met. The case was remanded for further proceedings concerning the settlement of Gregoria Mendoza's estate.
Ratio Decidendi
On whether the subject properties are reservable properties under Article 891 of the Civil Code: The Court found that Article 891 of the Civil Code on reserva troncal is not applicable. The fallacy in the CA's resolution was its premise that Placido was the ascendant contemplated in Article 891. The ownership of the properties should be reckoned from Exequiel, as he is the ascendant from whom the first transmission occurred, or from whom Gregoria inherited the properties. The law does not go farther than such ascendant/brother/sister in determining the lineal character of the property. It was immaterial whether Exequiel predeceased Placido and Dominga or whether Gregoria predeceased Exequiel; what was pertinent is that Exequiel owned the properties and is the ascendant from whom the properties originally came, and Gregoria is the descendant who received them by gratuitous title. On whether the petitioners are entitled to the reservation of the subject properties: The Court ruled that petitioners are not entitled to a reservation of the properties. Firstly, Julia Delos Santos, who held the properties, is not Gregoria's ascendant but a collateral relative. Article 891 requires the reservor to be an ascendant. Secondly, the petitioners are Gregoria's fourth-degree relatives (first cousins), and Article 891 reserves the property for relatives within the third degree. They cannot claim representation of their predecessors (Antonio and Valentin) because Article 891 grants a personal right of reservation only to relatives up to the third degree, with the exception of nephews and nieces representing their ascendants who are brothers/sisters of the prepositus. The Court clarified that the RTC erred in ordering reconveyance, as the reservista acquires absolute ownership subject to a resolutory condition, and the proper action would be to annotate the reservable character of the property on the title.
Main Doctrine
Reserva troncal under Article 891 of the Civil Code is not applicable when the person claiming the reservation is not an ascendant of the prepositus, and the claimed reservees are not relatives within the third degree of the prepositus from whom the property came.