On June 28, 2024, the Supreme Court reversed the trial court’s judgment finding the Estate of Silvestre Rogolifoi (“Silvestre Estate”) was entitled to one half of three properties inherited from Pedro Rogolifoi and proceeds from a related $2-million judgment.

The Supreme Court ordered the trial court to enter judgment in sole favor of the Estate of Rita Rogolifoi.

The trial court erroneously found that Silvestre’s heirs were not on notice that a 1953 Land Office decision determined that the land was owned only by the heirs of Rita Rogolifoi. The trial court stated that the property should have belonged to all heirs of Pedro Rogolifoi, Rita and Silvestre’s father, rather than Rita’s heirs alone. The court found that the statute of limitations did not prevent it from making this determination because Silvestre’s heirs would not have had notice that the representative for Rita’s estate was not acting as their trustee under Carolinian custom.

On appeal, the Supreme Court held that the 1953 Title Determination document did provide the heirs of Silvestre with notice that they did not own the land, because such determinations are presumed to provide adequate notice. The Supreme Court stated that Title Determinations from the Trust Territory administration should be read at face value, meaning that the courts should not ordinarily construe ownership beyond the parties actually named in the Title Determination.

Because the document in this case named only Rita Rogolifoi and not her brother or father, the land belongs only to her estate. The Supreme Court further held that land claim issues such as this one are bound by the 20-year statute of limitations, meaning Silvestre Estate’s claim expired in 1973 and this suit was brought almost 45 years too late.

The Supreme Court’s full opinion is available at https://cnmilaw.org/pdf/supreme/2024-MP-04.pdf. (PR)