**Facts:**
The case revolves around a dispute over the ownership of Lot 3368 in the Cadastral Survey of Ayuquitan (now Amlan), Oriental Negros. The property was originally owned by Saturnino Yaeso, who had children from two marriages. Upon Saturnino’s death, the property was distributed among his children, with Lot 3368 being allotted to his son Francisco Yaeso. Francisco died single and without descendants, at which point his mother, Andrea Gutang, assumed administration of the property and later sold it to appellants, Constancio Sienes and Genoveva Silay. When the appellants requested the surrender of the property’s title from Paulina Yaeso and Jose Esparcia, who had it in their possession, their request was refused. Consequently, a motion was filed but denied in the cadastral record No. 507. Subsequently, Cipriana and Paulina Yaeso, Francisco’s half-sisters, sold the property to the Esparcia spouses, who then got a transfer title issued in their name. The appellants filed a case seeking to nullify the sale to the Esparcias and for the property to be reconveyed to them.
**Issues:**
1. Whether Lot 3368 is a reservable property under Philippine law,
2. The validity of the sale made by Andrea Gutang to the appellants, and
3. The right of Cipriana Yaeso to inherit the property as a reservee.
**Court’s Decision:**
The Supreme Court held that:
1. Lot 3368 was indeed reservable property, given that Francisco Yaeso inherited it from his father, Saturnino, and upon Francisco’s death, it was passed to his mother, Andrea, who was obliged to reserve it for relatives within the third degree.
2. The sale made by Andrea Gutang to the appellants was subject to a resolutive condition and thus became ineffective upon Andrea’s death since Cipriana Yaeso was still alive, making her the absolute owner of the property.
3. Cipriana Yaeso, being a reservee and surviving Andrea Gutang, was entitled to the reservable property. Since the Esparcia spouses did not appeal the decision which ordered the reversion of the property to the estate of Cipriana Yaeso, the decision stands but without prejudice to any equitable action they may have against Cipriana Yaeso’s estate for reconveyance of the property.
**Doctrine:**
The Supreme Court elucidated the doctrine of reservable property (reserva troncal), which obliges the person who inherits a property (reservista) from an ascendant through legal succession to reserve that property for the relatives within the third degree who belong to the line from which the property originally came. It established that a reservista has legal title and dominion to the reservable property subject to a resolutive condition and may alienate it, but such alienation only transfers conditional ownership, revocable upon the survival of reservatarios at the time of the reservista’s death.
**Class Notes:**
– **Reservable Property (Reserva Troncal):** A legal institution where property received by a person from an ascendant is to be reserved for relatives within the third degree of the line from which the property came.
– **Reservista:** The individual who inherits the property and is obliged to reserve it for certain relatives.
– **Reservatarios:** The relatives within the third degree entitled to receive the reservable property upon the death of the reservista.
– **Resolutive Condition:** A future and uncertain event upon which the effectiveness or extinction of a legal relationship depends.
**Historical Background:**
This case highlights the application of the Spaniard-influenced doctrine of reservable property within the Philippine legal context, embodying the civil law principle aimed to keep property within a specific family lineage. The ruling ensures the observation of this tradition, recognizing the importance of lineage and inheritance rights under Philippine succession law.
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