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REPUBLIC v. CA

FACTS:

Amada Solano, the petitioner in this case, had been the personal domestic helper of the deceased Elizabeth Hankins for over three decades. In recognition of Solano's dedicated service, Hankins executed two deeds of donation in favor of Solano involving two parcels of land. Unfortunately, these deeds of donation were misplaced and could not be found.

With the deeds missing, the Republic filed a petition for escheat of Hankins' estate. The trial court then denied Solano's motion to intervene and proceeded to escheat the estate in favor of the Republic. As a result, the Registry of Deeds cancelled the original titles and issued new ones in the name of Pasay City.

At a later point, Solano claimed to have accidentally found the misplaced deeds of donation. Based on this discovery, she filed a petition for annulment of judgment, arguing that the properties were actually donated to her and should not have been included in Hankins' estate.

The Court of Appeals then issued a resolution giving due course to Solano's petition for annulment. This ultimately led to the filing of the present petition for certiorari, with Solano seeking to nullify the resolutions of the Court of Appeals.

ISSUES:

  1. Whether the Court of Appeals has jurisdiction to entertain the petition for annulment of judgment.

  2. Whether the properties in question are no longer part of the estate of the deceased Elizabeth Hankins at the time of her death.

  3. Whether the alleged donations are valid.

  4. Whether the cause of action is barred by the statute of limitations.

RULING:

  1. The Court of Appeals has jurisdiction to entertain the petition for annulment of judgment.

  2. The issue of whether the properties in question are no longer part of the estate of the deceased Elizabeth Hankins at the time of her death can only be resolved after a full-blown trial.

  3. The validity of the alleged donations can also only be determined after a full-blown trial.

  4. The cause of action is not barred by the statute of limitations as the petitioner is claiming ownership of the properties in question and seeking reconveyance, which has a prescription period of ten years.

PRINCIPLES:

  • Jurisdiction over the subject matter is determined by the allegations of the complaint.

  • The nature of the action determines the jurisdiction of the courts.

  • A cause of action for ownership and reconveyance has a prescription period of ten years.

  • If property is acquired through mistake or fraud, the person obtaining it is considered a trustee of an implied trust for the benefit of the person from whom the property comes.