SPS. AMADO v. NELLIE MANZANO

FACTS:

Nellie A. Manzano is a co-owner of Lot No. 113, CCs-167 along with her siblings. While Nellie was abroad, her siblings sold Lot No. 113 to Rolando Tinio, son of petitioners spouses Amado and Milagros Tinio, for P100,000. The sale was done through a forged "Affidavit of Waiver of Rights, Claim and Interest" that falsely stated Nellie's waiver of her rights over the property. Subsequently, Rolando Tinio acquired a Miscellaneous Sales Patent and registered it in the Registry of Deeds, resulting in Original Certificate of Title No. P-55907 being issued under his name. When Nellie returned to the Philippines, she attempted to redeem her co-owners' shares but received no response. She then filed a legal redemption action in the trial court. The trial court ruled in favor of Nellie, affirming her right of legal redemption. The court ordered Rolando Tinio to execute the necessary deed of sale transferring the property to Nellie and allowed him to withdraw the deposited redemption price. The Court of Appeals upheld the trial court's decision. The petitioners raised various arguments, including whether the property was part of the public domain. The Court of Appeals held that the issue of the property being part of the public domain could not be raised for the first time on appeal since it was not raised in the lower court. The parties also agreed during the pre-trial that Nellie is a co-owner of the property and that her siblings sold their shares to Rolando Tinio.

ISSUES:

  1. Whether the character of the land, whether public domain or private ownership, is an issue that can be raised on appeal.

  2. Whether the petitioner, who purchased the land from the co-owners of the respondent, is estopped from claiming that the respondent had no rights over the land.

RULING:

  1. The Court of Appeals ruled that the character of the land, whether public domain or private ownership, is not among the issues agreed upon by the parties in the lower court. The appellant cannot raise an issue that was not raised and ventilated in the lower court for the first time on appeal. Additionally, since the appellant purchased the land from the co-owners of the respondent, he is estopped from claiming that the respondent had no rights over the land.

  2. The Court of Appeals ruled that the appellant, having admitted that the respondent along with her brothers and sisters were co-owners of the subject property and that the co-owners sold their shares to the appellant, is estopped from claiming that the respondent had no rights over the land.

PRINCIPLES:

  • Issues not raised and ventilated in the lower court cannot be raised for the first time on appeal.

  • Estoppel can apply when a party has acted in a manner inconsistent with their claim and another party has relied on that inconsistent act to their detriment.