Heirs of Cornelio Miguel v. Heirs of Angel Miguel

Summary

This Supreme Court case involves a family property dispute between the heirs of brothers Cornelio and Angel Miguel over ownership of Lot J of Psd-146880. The conflict arose from a 1973 deed of donation where Cornelio and his wife donated land to Angel, but the deed contained an apparent clerical error in the property description. After Angel obtained title and subdivided the property to his sons, Cornelio's heirs filed suit claiming the donation was void due to the error and seeking reconveyance. The Supreme Court unanimously denied the petition, ruling that the doctrine of res judicata (conclusiveness of judgment) barred the action. The Court held that previous cases had necessarily adjudicated Angel's right to the property, and the Civil Code prohibition against reforming simple donations meant the original deed stood as written. The decision reinforces the finality of judgments and the technical description principle in property law, where land identity is determined by metes and bounds rather than lot designations.