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LILIA B. ADA v. FLORANTE BAYLON

FACTS:

The case involves the estate of spouses Florentino Baylon and Maximina Elnas Baylon. Spouses Baylon died in 1961 and 1974, respectively, and were survived by their legitimate children, including the petitioner Lilia B. Ada. Dolores, one of their children, died in 1976 without issue. Another child, Victoria, died in 1981 and was survived by her daughter Luz B. Adanza. Ramon, another child, died in 1989 and was survived by his child from his first marriage, Florante Baylon, as well as by his second wife, Flora Baylon, and their legitimate children.

In 1996, the petitioners filed a complaint for partition, accounting, and damages against Florante, Rita, and Panfila, alleging that after the death of Spouses Baylon, Rita took possession of several parcels of land and refused to effect a partition of the estate.

During the pendency of the case, Rita conveyed two parcels of land to Florante through a deed of donation. Rita died in 2000, and the petitioners filed a supplemental pleading seeking the rescission of the donation, alleging that Rita was already sick and weak when she executed the deed of donation. Florante and Panfila opposed the rescission.

The Regional Trial Court (RTC) rendered a decision, declaring the existence of co-ownership over certain parcels of land and directing their partition among the heirs of Spouses Baylon. The RTC also declared a co-ownership over the properties owned by Rita and directed their partition among her heirs. The RTC rescinded the donation inter vivos in favor of Florante.

The case involves a donation inter vivos made by Rita Baylon in favor of Florante Baylon, her nephew. The donation includes a lot numbered 4709 and half of another lot numbered 4706. The plaintiffs, who are the other heirs of Rita Baylon, filed a case for partition of the properties. They also sought to rescind the donation on the ground that it was made without their knowledge and approval. The trial court rescinded the donation involving the lots in question but clarified that it would not affect Florante's share in Rita's estate. Florante sought reconsideration, arguing that the lots were no longer part of Rita's estate as they were already donated to him. The trial court denied Florante's motion. On appeal, the Court of Appeals (CA) reversed the trial court's decision and held that a judicial ruling on the ownership of the lots is necessary before an action for rescission can be filed. The CA remanded the case to the trial court to determine the ownership of the lots. The petitioners sought reconsideration, but the CA denied it. The issue before the Supreme Court is whether the CA erred in ruling that the donation can only be rescinded if there is already a judicial determination of ownership.

ISSUES:

  1. Whether the CA erred in ruling that the donation inter vivos of Lot No. 4709 and half of Lot No. 4706 in favor of Florante may only be rescinded if there is already a judicial determination that the same actually belonged to the estate of Spouses Baylon.

RULING:

  1. Yes, the CA erred. The Supreme Court held that the RTC validly rescinded the donation inter vivos pursuant to Article 1381(4) of the Civil Code, given that Florante was a party to the partition case and the donation was made without the knowledge and approval of the petitioners or the RTC. A judicial determination of the parcels of land’s ownership was not a prerequisite for the rescissory action under Article 1381(4) of the Civil Code.

PRINCIPLES:

  1. Misjoinder of Causes of Action Joinder of actions is only permissible under the condition that it does not include special civil actions governed by special rules.

  2. Supplemental Pleadings A supplemental pleading can introduce a new cause of action as long as it relates to the original cause of action set in the complaint.

  3. Rescission of Contracts Rescission is a remedy to address damage or injury caused to contracting parties or third persons.

  4. Rescissible Contracts under Article 1381(4) Contracts that involve things under litigation and entered into by the defendant without the knowledge and approval of the parties concerned or judicial authority may be rescinded.

  5. Judicial Determination of Ownership For rescission under Article 1381(4) of the Civil Code, prior judicial determination of ownership is not necessary.

  6. Partition of Property The authority of the court to direct partition is limited to properties that are part of the estate under litigation.