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SULPICIA JIMENEZ v. VICENTE FERNANDEZ

FACTS:

The land in question is an Eastern portion with an area of 436 square meters of a residential land in Barrio Dulig, Pangasinan, originally owned by Fermin Jimenez. After Fermin's death, the land was registered under Act 496 in the names of Carlos Jimenez and Sulpicia Jimenez in equal shares pro-indiviso. Carlos Jimenez died, and his illegitimate daughter Melecia Cayabyab took possession of the eastern portion of the property.

Melecia Jimenez sold the 436 square-meter portion to Edilberto Cagampan, and defendant Teodora Grado entered into a contract titled "Exchange of Real Properties" where Melecia transferred the portion to her. Sulpicia Jimenez executed an affidavit adjudicating unto herself the other half of the property appertaining to Carlos Jimenez.

Sulpicia Jimenez filed a lawsuit to recover the eastern portion of the property occupied by defendant Teodora Grado and her son, but the lower court dismissed the complaint and declared Teodora Grado as the absolute owner of the land. The Court of Appeals affirmed the lower court's decision, and the motion for reconsideration was denied. In response, the petitioners appealed to the Supreme Court, presenting various assignments of error.

ISSUES:

  1. Whether Melecia Cayabyab is the daughter of Carlos Jimenez.

  2. Whether Melecia Cayabyab had the right to sell the land in question.

  3. Whether Edilberto Cagampan became the owner of the land through the deed of sale executed by Melecia Cayabyab.

  4. Whether Teodora Grado became the owner of the land through the deed of exchange executed with Edilberto Cagampan.

  5. Whether Sulpicia Jimenez's title over the land can be defeated by the adverse possession of Teodora Grado.

  6. Whether Teodora Grado is the absolute owner of the land in question.

  7. Whether the lower court erred in dismissing the complaint and ordering the appellants to pay attorney's fees.

RULING:

  1. The Supreme Court found merit in the petition. It ruled that the respondent court erred in not declaring that Melecia Cayabyab is not the daughter of Carlos Jimenez. The court held that there was no concrete evidence presented to prove that Melecia Cayabyab was indeed Carlos Jimenez's daughter. Even assuming she was his illegitimate daughter, she would have no right to succeed to his estate or to sell the land in question. Therefore, the lower court erred in ruling that Teodora Grado is the absolute owner of the land and in dismissing the complaint.

PRINCIPLES:

  • The burden of proof lies on the party alleging a fact, and the burden is not shifted to the other party unless the former has adduced evidence that proves the fact in issue. (Doctrine of Burden of Proof)

  • Illegitimate children have no right to inherit from their paternal relatives. (Civil Code)