Mariquita Sumaya and Laguna Agro-Industrial Coconut Cooperative v.

IAC
et.al
GR 68843-44
FACTS:
Raul Balantakbo inherited from two different ascendants two sets of parcels of
property, one from his father and the other from his maternal grandmother. Raul
died intestate, single and without any issue, leaving Consuelo Balantakbo, his
mother as sole heir. Subsequently, Consuelo adjudicated to herself the property in
affidavit stating that she is the sole and lone ascendant heir of Raul who left the
properties inherited from his father and grandmother. Consuelo sold the properties
to Mariquita Sumaya, who sold the same to Villa Honorio Development Corporation
which subsequently transferred its right over the property in favor of Laguna AgroIndustrial Coconut Cooperative. Certificates of title were issuedin Agros name.
However, such title do not contain any annotation of the property being reservable
in character. Two years after Consuelos death, Amadeo et al, brothers, sisters,
nephew and nieces of Raul filed a civil case for the recovery of the parcels of land
sold to Agro alleging that such is subject of reserva troncal. Court a quo ruled in
favor of plaintiffs, finding Agro as not innocent purchasers for value. The CA
affirmed the lower courts decision and ruled that there is no need to annotate the
reservable interest of reserves in property covered by the certificate of title.
ISSUE:
Whether there is a need to annotate the reservable character of the property
subject of reserva troncal
RULING:
Yes. In a ruling decided by the Court, the reservable character of a property may be
lost to innocent purchasers for value and hence, the obligation is imposed on a
widowed spouse to annotate the reservable character of a property subject of
reserve viudal. Such obligation is also applicable in reserva troncal. Moreover, the
purpose of notation is nothing more than to afford the persons entitled to
reservation, if any, due protection against any act of the reservoir, which may make
it ineffective.