Dizon v. Galang
REITERATIONFacts
1. The Antecedents: Rufina Dizon inherited three parcels of land from her parents. She married Vicente Galang, and they had a son, Francisco. Rufina Dizon and her son Francisco died in 1904. By operation of law, Vicente Galang inherited the lands from his son, Francisco, who had inherited them from his mother, Rufina Dizon. These lands were considered reservable property under Article 811 of the Civil Code. In 1913, Vicente Galang sold two of these parcels to Juan Medina and in 1909 sold the third parcel to Teodoro Jurado, without disclosing their reservable character. 2. Procedural History: Pedro and Severina Dizon, siblings of the deceased Rufina Dizon and thus related within the third degree, initiated this action against Vicente Galang, Juan Medina, and Teodoro Jurado. They sought to have the sales of the land by Vicente Galang to Medina and Jurado annulled, to compel Vicente Galang to register the reservable character of the land, and to have him execute a mortgage securing the value of the property. The trial court dismissed the complaint, ordering the plaintiffs to pay costs. The plaintiffs appealed this decision. 3. The Petition: The plaintiffs-appellants, Pedro and Severina Dizon, are appealing the lower court's decision that dismissed their complaint. They argue that the sales of the reservable property by Vicente Galang to Juan Medina and Teodoro Jurado should be set aside or that Vicente Galang should be compelled to register the reservable character of the land and provide security for its value. The core of their argument hinges on the nature of reservable property and the obligations of the vendor and purchasers concerning such property, particularly when sold without proper disclosure of its reservable status.
Issue(s)
Whether the sales of reservable property made by Vicente Galang to Juan Medina and Teodoro Jurado can be set aside. Whether Vicente Galang can be compelled to record the reservable character of the land in the registry of deeds. Whether Vicente Galang can be compelled to execute a mortgage to secure the value of the land.
Ruling
The Supreme Court affirmed the appealed judgment, dismissing the complaint with costs against the plaintiffs-appellants. The sales of the reservable property were upheld, and the defendants-appellees were not compelled to return the land, record its reservable character, or execute a mortgage.
Ratio Decidendi
On the validity of the sales of reservable property: The Court held that the sales made by Vicente Galang of the three parcels of land, which are reservable property, in favor of Juan Medina and Teodoro Jurado, cannot be set aside unless the resolutory condition imposed by the reservation shall have occurred. Article 975 of the Civil Code permits the sale of reservable property by the widower, after contracting a second marriage, subject to the reservation as a resolutory condition. However, the Court noted that the sales in this case were made before the reservation had arisen in its full effect, or at least, before the occurrence of the resolutory condition. The Court also emphasized that Juan Medina and Teodoro Jurado acquired the land in good faith, free of all incumbrances, and that the reservation will follow the property. The Court distinguished this from a reservation by a widowed spouse, where property sold during the first stage (before becoming reservable) is absolutely free, but if sold during the second stage (after the duty to reserve has arisen), it is subject to the reservation. In reserva troncal, the property goes to the ascendant already reservable in character, and a sale might be analogous to a sale made by the widower after a second marriage. On compelling Vicente Galang to record the reservable character of the land: The Court ruled that since the parcels of land had been legally transferred to third persons, Vicente Galang had lost ownership thereof and could not compel the registration of their reservable character. He could not affect the fee simple, which did not belong to him, to the damage of Juan Medina and Teodoro Jurado, who acquired the land in good faith. The Court also noted that there was no prayer in the complaint to compel the purchasers to acknowledge the reservation and note the same in their deeds. On compelling Vicente Galang to execute a mortgage: The Court held that Vicente Galang could not be compelled to execute a mortgage to secure the value of the three parcels of land. The Court explained that the rules established for reservation by a widowed spouse to secure the value of property sold before it becomes reservable are not applicable to reserva troncal where the property goes to the ascendant already reservable in character. In reserva troncal, the reservation follows the property, and there is no need to secure the value since the property itself is liable for the efficacy of the reservation, without prejudice to the rights of innocent purchasers.
Main Doctrine
Sales of reservable property made by the ascendant (reservista) after inheriting from the descendant (descendant of the first marriage) are valid and cannot be set aside unless the resolutory condition imposed by the reserva troncal shall have occurred. The reservation follows the property, and the ascendant loses ownership thereof and cannot register its reservable character. Third persons who acquired the land in good faith are protected.