Case Number: 3 G.R. Number: 132305 Case Title: LABAGALA VS.

SANTIAGO Date: December 4, 2001

FACTS: Jose T. Santiago was part owner of a parcel of land under TCT No. 64729 Along with his sisters Nicolasa and Amanda. Upon Joses death on February 6, 1984, his sisters filed a petition on August 5, 1987 to claim the 1/3 of land who came into the possession of Ida Labagala upon Joses death. The sisters, in the first complaint said that the sale to Labagala by the late Jose was made through the machinations of the latter. On Labagalas defense however, she petitioned that she is the daughter of Jose, therefore had the right to the said land. ISSUE: The main issue in this case is to reverse the decision of the court of appeals, which reversed the decision of the regional trial court. The regional trial court first ruled in favour of Labagala, for they agreed to the idea that indeed, Labagala was the daughter of Jose and therefore had the right to the one third of the parcel of land. However, upon Nicolasa and Amandas appeal, this decision was reversed by the court of appeals due to lack of evidence by Labagala that she was indeed the daughter of Jose. This made Labagala try to reverse the decision of the court of appeals, by insisting that the land was donated to her. But to no avail, this claim was also not proven. DECISION: The ruling of the court of appeals was not reversed, therefore the land was transferred to Nicolasa and Amanda. RATIONALE: In the case of Labagala, she cited article 263 of the civil code in her defense as the daughter of Jose. However, this article is misplaced because it states that: The action to impugn the legitimacy of the child shall be brought within one year from the recording of the birth in the Civil Register, if the husband should be in the same place, or in a proper case, any of his heirs. If he or his heirs are absent, the period shall be eighteen months if they should reside in the Philippines; and two years if abroad. If the birth of the child has been concealed, the term shall be counted from the discovery of the fraud.

This article refers only to the LEGITIMACY of the child, whereas Nicolasa and Amanda contends not if Labagala is legitimate or not, but that she is not the child at all of Jose, which gives her no right to the land. And with regards to this issue, the sisters were able to show, through Labagalas birth certificate, that she was indeed born from different parents. The courts gave Labagala the chance to show any document that could prove otherwise, and yet she failed to do so. As to Labagalas plea that the sale was indeed a donation, the courts found many defects on it. First is why did Jose wanted to hide the donation as a sale? Second is why did Jose, who was fully aware that he only owned 1/3 of the land, donated the whole parcel of land to Ida? Third, is that why did a college graduate like Jose Santiago, only affixed his thumb mark on the deed of sale, when he couldve signed his name instead? Fourth is that why did Jose affix his thumb mark on a deed which stated falsely that he was single, when he was indeed married? And lastly, if Jose did recognize Ida Labagala as his daughter, then what was the point of donating the land to her, if later on she will inherit it as his daughter upon his death anyway? And during Joses death, even if it was really a donation, the donation couldnt have been perfected since Labagala was already 15 years old then and needed the approval of a guardian for the said donation. Labagala showed none, which only made it clearer to the courts that there really was no donation at all. Therefore, Labagalas petition to reverse the decision of the court of appeals was denied.