ObliCon Case Batch 1:

(1) Pangasinan vs. Almazora, GR No. 200558, July 1, 2015

(2) Spouses Rol vs. Racho, GR No. 246096, January 13, 2021
(3) Heirs of Alido vs. Campano, GR No. 226065, July 29, 2019
(4) Morales vs. CFI of Misamis Occidental, GR No. L-52278, May
29, 1980
(5) Lorenzo, Et. Al. Vs. Eustaquio, Et. Al., GR No. 209435, August
10, 2022
(6) Ocampo vs. Ocampo, GR No. 227894, July 5, 2017
(7) Canlas vs. Republic, G. R. 200894, November 10, 2014
(8) Dailisan vs. CA, GR No. 176448, July 28, 2008
(9) Republic vs. Sereno, GR No. 237428, June 19, 2018
10) Ruña vs. Lead Export, GR No. 225896, July 23, 2018
(1) Pangasinan vs. Almazora, GR No. 200558, July 1, 2015

Facts:
 Complaint for damages filed by Aurora Morales-Vivar and her
heirs against the heirs of Conrado Almazora. Allegation of
fraudulent transfer of a property title. Subject property is a
parcel of land located in Biñan, Laguna. Originally registered
in the name of Aquilina Martinez under Transfer Certificate of
Title (TCT) No. T-18729. Title transferred to Aurora Morales-
Vivar, her sole heir, after Aquilina's death. Aurora discovered
that the title had been transferred to Conrado Almazora and
sold to Fullway Development Corporation without her
authorization.

Issue:
 Whether the transfer of the property title was fraudulent.
 Whether the complaint for damages is barred by prescription
and laches.

Ruling:
 The Supreme Court upheld the decisions of the lower courts.
The complaint for damages is dismissed. Aurora and her
heirs are barred by laches. The action has prescribed. Aurora
failed to prove her claim of fraudulent transfer of the
property title.

Ratio:
 Aurora and her heirs are barred by laches because they
failed to assert their rights over the property for an
unreasonable length of time. The action has prescribed as
the prescriptive period to recover property obtained through
fraud has already lapsed. Aurora failed to prove the fraud
alleged in her complaint.
(2) Spouses Rol vs. Racho, GR No. 246096, January 13, 2021

Facts:
 Respondent Isabel Urdas Racho alleged that her brother,
Loreto Urdas, was the registered owner of a parcel of land
denominated as Lot No. 1559. Loreto died without any issue,
leaving his siblings, Fausto, Chita, Maria, and Isabel, as his
intestate heirs to the said lot. Isabel discovered that the lot
was subdivided into two portions, Lot Nos. 1559-A and 1559-
B. The petitioners made it appear that Loreto sold the
subdivided lots to them through forged deeds of sale. New
titles were issued in the petitioners' names. Isabel filed a
complaint for reivindicacion and damages against the
petitioners.

Issue:
 Whether the sale of the land to the petitioners is valid.

Ruling:
 The sale of the subdivided lot to the petitioners is valid only
insofar as half of the aggregate undivided interest of certain
heirs is concerned. The forged deeds of sale and the
extrajudicial settlement with sale (EJSS) were declared null
and void. The inchoate interests of the parties over the lot
were recognized. The lot was ordered to be reconveyed to
the intestate estate of Loreto Urdas.

Ratio:
 The Court declared the forged deeds of sale as null and void,
as they were executed without the knowledge and consent
of Isabel. The EJSS was also declared null and void, as it was
executed without the knowledge and consent of Isabel. The
Court recognized the intent of Fausto, Chita, and Maria to
sell their inchoate interest over the lot to the petitioners, but
only through an oral contract of sale. The Court recognized
the respective inchoate interests of the parties over the lot.
 The Court ordered the reconveyance of the lot to the
intestate estate of Loreto Urdas.

(3) Heirs of Alido vs. Campano, GR No. 226065, July 29, 2019

Facts:
 The case involves a parcel of land in Barangay Abang-Abang,
Alimondian, Iloilo covered by Original Certificate of Title
(OCT) No. F-16558 and registered under the name of
Soledad Alido. Flora Campano, the respondent, claimed to
have purchased the property from Alido in 1978 and had
been in possession of the land since then. After Alido's
death, her heirs executed a Deed of Adjudication and sought
to register the property in their names. Campano refused to
surrender the owner's duplicate of OCT No. F-16558. The
heirs filed a petition before the Regional Trial Court (RTC) for
the surrender of the title. The RTC ruled in favor of the heirs,
stating that Alido's right as the registered owner cannot be
defeated by prescription and that the oral sale between Alido
and Campano was not valid because it violated the
requirement of a public instrument for the sale of real
property. Campano appealed to the Court of Appeals (CA),
which reversed the RTC's decision. The CA held that an oral
sale of real property is not void, but only unenforceable
under the Statute of Frauds. The CA also noted that the sale
between Alido and Campano was void because it violated
the five-year prohibition on alienation of lands acquired
through a free patent application. The CA further ruled that
the heirs' action was barred by laches due to their delay in
asserting their rights. The Supreme Court (SC) reversed the
CA's decision and ruled in favor of the heirs. The SC held that
a Torrens Title is indefeasible and cannot be defeated by
adverse possession or prescription. The SC clarified that the
 Statute of Frauds does not render an oral sale of real
property void, but only unenforceable. In this case, the sale
between Alido and Campano was void because it violated
the five-year prohibition on alienation. The SC also held that
laches does not apply when the assailed contract is void ab
initio. The heirs can still challenge the sale and recover the
property. The case was remanded to the RTC to determine
the amount of purchase price Campano may recover and
whether the fruits she had enjoyed from the possession of
the land would compensate for the interest on the price.

Issue:
 Whether the sale between Alido and Campano is valid
despite being an oral sale and violating the five-year
prohibition on alienation of lands acquired through a free
patent application.
 Whether the heirs' action is barred by laches due to their
delay in asserting their rights.

Ruling:
 The Supreme Court (SC) ruled in favor of the heirs. The sale
between Alido and Campano is void because it violated the
five-year prohibition on alienation of lands acquired through
a free patent application. Laches does not apply when the
assailed contract is void ab initio. The heirs can still
challenge the sale and recover the property. The case was
remanded to the RTC to determine the amount of purchase
price Campano may recover and whether the fruits she had
enjoyed from the possession of the land would compensate
for the interest on the price.

Ratio:
 A Torrens Title is indefeasible and cannot be defeated by
adverse possession or prescription. The Statute of Frauds
does not render an oral sale of real property void, but only
unenforceable. In this case, the sale between Alido and
Campano was void because it violated the five-year
 prohibition on alienation. Laches does not apply when the
assailed contract is void ab initio. The heirs can still
challenge the sale and recover the property. The case was
remanded to the RTC to determine the amount of purchase
price Campano may recover and whether the fruits she had
enjoyed from the possession of the land would compensate
for the interest on the price.

(4) Morales vs. CFI of Misamis Occidental, GR No. L-52278, May

29, 1980

Facts:
 Complaint for recovery of possession and ownership of a
property filed by Marciana De Morales against Felicidad
Busarang and Fortunato Gonzaga. Complaint filed on May 7,
1978, in the Court of First Instance of Misamis Occidental,
Branch II at Ozamis City. Complaint similar to a previous
case, Civil Case No. 2031, filed on September 26, 1957, by
Rosario Morales-Terez and Santiago Terez against the same
respondents. Previous case dismissed for failure to prosecute
but later modified to be without prejudice.

Issue:
  Whether the action for recovery of possession and ownership
of the property is barred by prescription.

Ruling:
 Supreme Court set aside the trial court's dismissal of the
complaint and ordered the reinstatement of Civil Case No.
OZ-704. Action had not yet prescribed and defendants had
not proven acquisitive prescription.

Ratio:
 Two kinds of prescription provided in the Civil Code:
acquisitive prescription and extinctive prescription.
Acquisitive prescription refers to the acquisition of a right by
the lapse of time. Extinctive prescription refers to the loss of
rights and actions by the lapse of time. In this case,
extinctive prescription is involved since the action is for the
recovery of real or immovable property. Article 1141 of the
Civil Code states that real actions over immovables prescribe
after thirty years. Less than thirty years had elapsed from
the date of the previous dismissal of the case, so the action
had not yet prescribed. Defendants did not claim acquisitive
prescription in their answer, and even if they did, it cannot
be given judicial sanction based on mere allegations. Law
requires the party asserting ownership by adverse
possession to prove the presence of essential elements such
as good faith, a just title, and the lapse of time fixed by law.
Trial court erred in dismissing the complaint based on
prescription, and the case should be reinstated.

(5) Lorenzo, Et. Al. Vs. Eustaquio, Et. Al., GR No. 209435, August
10, 2022

Facts:
 The case involves a dispute over ownership of a parcel of
land in Camiling, Tarlac. The land was originally owned by
 the spouses Gregorio Eustaquio and Regina Lorenzo. In
1942, they executed a deed of donation propter nuptias,
donating the land to their son Delfin and his wife Fortunata.
Delfin and Fortunata occupied and possessed the land until
Delfin's death in 1994. After Delfin's death, the petitioners,
who are heirs of Gregorio and Regina, presented a Deed of
Succession and Adjudication, claiming ownership of the land.
The respondents, heirs of Delfin and Fortunata, filed a
complaint for quieting of title, declaration of nullity of
documents, surrender of title, and damages, asserting their
ownership over the land based on the donation propter
nuptias. The Regional Trial Court (RTC) ruled in favor of the
respondents, declaring the donation propter nuptias void for
lack of notarization but awarding ownership of the land to
them based on laches. The RTC also declared the Deed of
Succession and Adjudication null and void. The Court of
Appeals affirmed the RTC's decision.

Issue:
1. Whether the lack of a subject index in the appellants' brief
warrants the dismissal of the appeal.
2. Whether the spouses Delfin and Fortunata are the rightful
owners of the land.
3. Whether the Deed of Succession and Adjudication is valid.
4. Whether respondents are entitled to the award of damages.

Ruling:
 The lack of a subject index in the appellants' brief is a
procedural defect that warrants the dismissal of the appeal.
However, the Court still discussed the substantial merits of
the case and found no reversible error in the lower courts'
decisions. The donation propter nuptias was void for lack of
notarization. The respondents acquired ownership of the
land through laches. The Court declared the Deed of
Succession and Adjudication null and void. The Court
affirmed the award of moral damages and attorney's fees to
the respondents.
Ratio:
 The lack of a subject index in the appellants' brief is a
procedural defect that warrants the dismissal of the appeal.
However, the Court still discussed the substantial merits of
the case and found no reversible error in the lower courts'
decisions. The donation propter nuptias was void for lack of
notarization. This means that the donation was not legally
valid and did not transfer ownership of the land to Delfin and
Fortunata. However, the respondents acquired ownership of
the land through laches. Laches is a legal doctrine that
applies when a person fails to assert their rights for an
unreasonable and unexplained length of time, causing
prejudice to the other party. In this case, the respondents
had been in peaceful, uninterrupted, and adverse possession
of the land for 50 years, while the petitioners and their
predecessors-in-interest failed to assert their claim or
contest the respondents' possession. Therefore, the
respondents' possession had ripened into ownership by
reason of laches. The Court declared the Deed of Succession
and Adjudication null and void because the respondents had
already acquired ownership of the land at the time it was
executed. The Deed of Succession and Adjudication was
therefore unnecessary and had no legal effect. The Court
affirmed the award of moral damages and attorney's fees to
the respondents. This is because the respondents were able
to prove that they suffered moral damages as a result of the
petitioners' actions, and they were also entitled to attorney's
fees for the expenses they incurred in pursuing their case.
(6) Ocampo vs. Ocampo, GR No. 227894, July 5, 2017

Facts:
 Legal battle between brothers, Jose S. Ocampo (petitioner)
and Ricardo S. Ocampo, Sr. (respondent). Dispute over the
partition and annulment of a property title. Property is a
conjugal property left by their parents, consisting of a 150-
square meter lot and improvements located in Manila.
Property originally registered in parents' names under TCT
No. 36869. Respondent alleges petitioner and his wife
conspired in falsifying his signature on a notarized Extra-
Judicial Settlement with Waiver (ESW). Transfer of property
made in petitioner's name under TCT No. 102822.
Respondent claims petitioner refused to partition the
property and secretly mortgaged it for P200,000.00

Issue:
1. Whether the signature of the respondent on the ESW is
genuine.
2. Whether the ESW is a void or inexistent contract.
3. Whether the action to declare the nullity of the ESW is
barred by laches.

Ruling:
 Supreme Court affirmed the decision of the Court of Appeals
(CA). Ordered the partition of the subject property.
Respondent was able to prove that his signature on the ESW
was not genuine. Action to annul the ESW is imprescriptible
since it is a void or inexistent contract. Action was not barred
by laches
Ratio:
 Action for annulment of title and partition has not prescribed
as respondent was in actual possession of the disputed land
at the time of filing the complaint. Action for reconveyance
based on an implied or constructive trust generally
prescribes in ten years, but if plaintiff remains in possession
of the property, prescriptive period does not run against him.
Respondent's complaint may be treated as an action for
quieting of title, which is imprescriptible. Action was not
barred by laches as respondent filed multiple cases to assert
his rights and did not unreasonably delay in pursuing his
claims against the petitioner.

(7) Canlas vs. Republic, G.R. 200894, November 10, 2014

Facts:
 Petitioner Luzviminda Canlas applied for the original
registration of title for a 9,751-square-meter parcel of land in
Binangonan, Rizal. The trial court granted Canlas'
application, stating that she has been in open, continuous,
exclusive, and notorious possession of the land for more
than 30 years. The Court of Appeals reversed the decision,
stating that Canlas failed to prove her possession and
occupation of the property. Canlas appealed to the Supreme
Court, arguing that she has shown sufficient evidence of her
possession and occupation of the land.

Issue:
1. Whether Canlas has proven open, continuous, exclusive, and
notorious possession and occupation of the land.
2. Whether the land is covered by TCT No. 23377.

Ruling:
  The Supreme Court granted Canlas' petition and reversed
the decision of the Court of Appeals. The case was remanded
to the trial court to determine whether the land is included in
TCT No. 23377.

Ratio:
1. The burden of proof rests on the applicant to prove open,
continuous, exclusive, and notorious possession and
occupation of the land.
 Canlas has sufficiently shown acts of dominion over the
land through her and her predecessors-in-interest's
farming activities, payment of taxes, declaration of the
property, employment of a caretaker, and other acts of
ownership.
2. Tax declarations are not conclusive evidence of ownership,
but they can be weighed in favor of the applicant when
coupled with positive and clear testimonies.
 The fact that the property was not regularly declared
for tax purposes does not automatically contradict the
claim of possession.
3. The issue of whether the land is covered by TCT No. 23377
was remanded to the trial court for further proceedings.
 The alleged certification provided by Canlas at a late
stage in the proceedings requires verification and
should be threshed out in the trial court to ensure due
process and avoid future disputes.
(8) Dailisan vs. CA, GR No. 176448, July 28, 2008

Facts:
 Jose S. Dailisan filed a complaint for partition against
Federico Pugao. Dailisan claimed that he purchased one-
fourth of the land from Pugao. Initially, Dailisan agreed to
purchase half of the land but was later informed by Pugao
that he could only sell one-fourth. They executed a deed of
real estate mortgage and, after the loan was paid, a deed of
absolute sale. Dailisan requested the partition of the land,
but Pugao refused to comply. Pugao claimed that he allowed
Dailisan to occupy one-fourth of his land out of pity when
Dailisan's house was demolished. Pugao admitted to
executing a deed of real estate mortgage but denied
voluntarily executing the deed of absolute sale, alleging that
he was made to sign pages of the document without fully
understanding its contents. The trial court ruled in favor of
Dailisan, ordering the partition of the property and the
 execution of necessary documents. The Court of Appeals
reversed the decision, finding the deed of sale fictitious and
invalid. The Court of Appeals also ruled that Dailisan's action
for specific performance had already prescribed.

Issue:
 Whether the deed of absolute sale is valid
 Whether Dailisan's action for partition is also an action for
specific performance
 Whether the respondents' failure to file an action for
annulment of the deed of sale within the prescribed period
affects its validity

Ruling:
 The deed of absolute sale is valid.
 Dailisan's action for partition is also an action for specific
performance.
 The respondents' failure to file an action for annulment of
the deed of sale within the prescribed period does not affect
its validity.

Ratio:
 The burden of proof to overcome the presumption of due
execution of a notarized document lies on the party
contesting such execution.
 The respondents failed to file an action for annulment of the
deed of sale within the prescribed period, thereby losing
their right to set up the nullity of the deed as a defense.
 Dailisan's action for partition, which is also an action for
specific performance, does not prescribe because it is a right
inherent in his co-ownership of the property.
 Ownership of the portion sold to Dailisan was already
acquired through the execution of the deed of absolute sale
and the delivery of the property.
Conclusion:
 The Supreme Court granted Dailisan's petition, setting aside
the decision of the Court of Appeals and reinstating the
decision of the trial court.
 The Court affirmed the validity of the deed of absolute sale
and recognized Dailisan's right to partition the property.

(9) Republic vs. Sereno, GR No. 237428, June 19, 2018

Facts:
 The case involves a petition for quo warranto filed by the
Republic of the Philippines against Maria Lourdes P. A.
Sereno, the Chief Justice of the Supreme Court. The petition
seeks to invalidate Sereno's appointment as Chief Justice
 due to her failure to regularly disclose her assets, liabilities,
and net worth (SALNs), which is a requirement for members
of the Judiciary. The Republic argues that Sereno's failure to
file the required disclosures and submit them to the Judicial
and Bar Council (JBC) shows that she lacks the "proven
integrity" demanded of every aspirant to the Judiciary. The
Republic seeks the nullification of Sereno's appointment and
her ouster from the position of Chief Justice.

Issue:
 Whether Sereno's failure to file her SALNs and submit them
to the JBC disqualifies her from holding the position of Chief
Justice.

Ruling:
 The Supreme Court grants the petition for quo warranto and
invalidates Sereno's appointment as Chief Justice. The Court
holds that the failure to file SALNs and submit them to the
JBC is a violation of the Constitution, the Anti-Graft Law, and
the Code of Conduct and Ethical Standards for Public
Officials and Employees. The Court emphasizes the
importance of integrity in the Judiciary and the Court's power
to determine qualifications for public office. The Court
concludes that Sereno's failure to comply with the SALN
requirement renders her ineligible for the position of Chief
Justice.

Ratio:
 The failure to regularly disclose assets, liabilities, and net
worth, as required by law, is a violation of the Constitution
and other relevant laws. This failure demonstrates a lack of
integrity, which is an essential qualification for members of
the Judiciary. Therefore, Sereno's appointment as Chief
Justice is invalidated through a petition for quo warranto.

10) Ruña vs. Lead Export, GR No. 225896, July 23, 2018
Facts:
The case involves a dispute over two parcels of land in the
Philippines. The petitioner, Carmen Aledro-Ruña, filed an
appeal against the respondent, Lead Export and Agro-
Development Corporation. The Court of Appeals denied her
appeal for lack of merit. The petitioner seeks to reverse the
decision and have a new judgment declaring her as the rightful
possessor of the land. The case originated from three civil
cases involving two parcels of land registered under the name
of Segundo Aledro. Segundo allegedly executed a lease
contract with Alfredo Rivera in 1972 and a deed of absolute
sale with Mario Advento in 1981. Advento later sold the
properties to Andres Ringor in 1982. In 1988, Farmingtown
Agro-Developers, Inc. (FADI) leased the land from Ringor for 25
years. The first case, Civil Case No. 95-13, was filed by the
heirs of Segundo against Advento and FADI for real action over
an immovable, declaration of nullity of deed, and damages. The
Regional Trial Court (RTC) dismissed the complaint, but the
Court of Appeals reversed and remanded the case for further
evidence. The heirs, including the petitioner, filed a motion to
dismiss with prejudice, and the RTC granted it. The dismissal
order became final and executory. The second case, Civil Case
No. 41-2005, was filed by Sofia, the widow of Segundo, against
Advento for the declaration of nullity of the deed of sale and
quieting of title. The RTC ruled in favor of Sofia, declaring the
deed of sale null and void. The decision became final and
executory. The present case, Civil Case No. 218-10, was filed
by the petitioner for unlawful detainer, damages, and
attorney's fees against the respondent. The Municipal Circuit
Trial Court (MCTC) ruled in favor of the petitioner, but the RTC
reversed the decision for lack of jurisdiction. The RTC dismissed
the case, citing res judicata and upholding the validity of the
deeds of sale and the lease contract between Ringor and the
respondent. The Court of Appeals affirmed the RTC's decision,
applying the principle of res judicata and ruling that the
petitioner's action had already prescribed. The petitioner
appealed to the Supreme Court.
Issue:
 Whether the principle of res judicata should be applied in
this case.
 Whether the subsequent buyers of the land were buyers in
bad faith.
 Whether the petitioner's action to recover possession is
barred by prescription or laches.

Ruling:
 The Supreme Court held that the principle of res judicata
should be disregarded in this case because the dismissal
order in the first case was not a judgment on the merits. The
Court also noted that the dismissal was upon motion of the
plaintiffs, without sufficient legal basis. The Court further
ruled that the subsequent buyers of the land, including the
respondent, were buyers in bad faith. The unregistered
deeds of sale and the failure to transfer the certificates of
title to the subsequent buyers indicated that the
transactions were questionable.The Court concluded that the
petitioner, as an heir of the registered owner, had a better
right to possess the land. The Court also held that the
petitioner's action to recover possession was not barred by
prescription or laches. An action to recover possession of
registered land does not prescribe, and laches cannot be set
up to resist the enforcement of an imprescriptible legal right.
Therefore, the Supreme Court granted the petitioner's
appeal, reversed the decision of the Court of Appeals, and
reinstated the decision of the MCTC in favor of the petitioner.

Ratio:
 The dismissal order in the first case was not a judgment on
the merits, and therefore, the principle of res judicata should
not be applied.
 The subsequent buyers of the land were buyers in bad faith
due to the unregistered deeds of sale and the failure to
transfer the certificates of title.
 The petitioner, as an heir of the registered owner, had a
better right to possess the land.
 The petitioner's action to recover possession was not barred
by prescription or laches.
 An action to recover possession of registered land does not
prescribe, and laches cannot be set up to resist the
enforcement of an imprescriptible legal right.