Facts:

The case involves a legal dispute between Eriberto Alforque, as judicial administrator of the estate of the deceased Ricario Veloso, and Juan Veloso (plaintiffs/appellees) against Gabino R. Veloso, individually and as administrator of the estate of the deceased Josefa Garces, et al. (defendants/appellants). The litigation arose from the properties that were allegedly owned by Rafael Veloso, the husband of Josefa Garces. The plaintiffs claimed that these properties were passed to Josefa by way of usufruct upon Rafael's death, and upon her death, automatically passed to the heirs of Rafael, specifically the heirs include Juan Veloso and Ricario Veloso.

Rafael Veloso had nine legitimate children with Josefa Garces. He executed a valid open will instituting his children and a natural child, Arsenio de la Cerna, as his sole heirs. A partition was agreed upon on August 20, 1906, wherein properties were divided among the heirs, including Josefa who was appointed guardian over the m

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Facts:

Parties and Estate Background

• The litigation involved plaintiffs – Eriberto Alforque as judicial administrator of the deceased Ricario Veloso’s estate and Juan Veloso – and defendants led by Gabino R. Veloso, who acted on his own behalf and as administrator of the deceased Josefa Garces’ estate.
• The properties in dispute were those described in paragraph VII of the complaint, originally part of the estate of Rafael Veloso.

Family Relations and Testamentary Provisions

• Rafael Veloso, during his lifetime, married Josefa Garces on January 16, 1882, and they had nine children together (including Juan Veloso, Ricario Veloso, Agripina, Gorgonio, Eriberta, Martina, Carmen, Gabino Roberto, and Rafael Miguel Veloso).
• Prior to his marriage, Rafael Veloso had a natural child, Arsenio Veloso (or Arsenio de la Cerna), whom he duly acknowledged.
• An open will executed by Rafael Veloso before his death on October 6, 1897, appointed all his legitimate children and his natural child as heirs, with special provisions:

- The “Fifth” clause declared the legitimate children as his sole and universal heirs. - The “Second” clause stated that Josefa Garces, as his lawful wife, contributed nothing to the marriage, emphasizing his monetary contribution received by way of legatee.

Extrajudicial Partition and the Agreement

• Upon the death of Rafael Veloso, the estate remained undivided, leading to negotiations among the heirs and the then widowed Josefa Garces.
• In order to facilitate the partition without judicial intervention, the parties executed a deed of partition on August 20, 1906 (marked as Exhibit B), which:

- Listed a detailed inventory of the properties. - Formed a schedule of shares, whereby each party’s respective share was delineated and included a renunciation clause whereby each party waived any right over properties assigned to the other.

Subsequent Developments and Administration of the Estate

• Josefa Garces, who later executed her own will (probated in 1927) and appointed Gabino Veloso as executor, continued to possess, manage, and treat certain properties as her exclusive property for over two decades.
• Evidence showed that from the time of the partition in 1906 until her death in 1927, Josefa Garces acted openly and continuously as the owner of the properties adjudicated to her, including through acts of possession and even by selling parts of the properties later on.

Claims and Controversies Raised by the Parties

• Plaintiffs asserted that the properties should be deemed those of Rafael Veloso, contending that:

- The rights conferred to Josefa Garces were only by way of widow’s usufruct and not full ownership. - Following her death, the properties should automatically revert and be partitioned among the heirs of Rafael Veloso. - Argued that Josefa Garces had been in open, continuous, and adverse possession as the sole owner for more than 23 years. - Presented supplementary arguments regarding prescription, renunciation by forced heirs (including an alleged renunciation by Juan Veloso and Ricario Veloso), and the binding nature of the extrajudicial partition.

Legal and Procedural Timeline

• The extrajudicial partition was executed on August 20, 1906, and subsequent acts of ownership by Josefa Garces and acknowledgment by the other heirs persisted for over 24 years until the filing of the complaint on October 15, 1930.
• The lower court initially decided in favor of the plaintiffs, ordering the partition of the contested properties.
• On appeal, the defendants challenged numerous findings and errors, ultimately leading to an appellate review of the entire matter.

Issue:

• Whether the properties partitioned in 1906 and adjudicated to Josefa Garces were granted to her in full ownership or merely by way of usufruct, in light of the provisions of Rafael Veloso’s will and the extrajudicial partition agreement.

• Whether the extrajudicial partition agreement, particularly the renunciation clause by which each party waived any future claim over properties assigned to others, is binding and conclusive upon the parties.

• Whether the continuous, open, adverse, and uninterrupted possession by Josefa Garces for more than two decades (and the subsequent acts of the heirs) constitutes sufficient basis for acquiring ownership by prescription, thereby precluding any claim from other heirs.

• Whether the defendants’ allegations regarding errors in the lower court’s proceedings—such as the improper admission of evidence, the mischaracterization of property rights, and the failure to recognize the effects of renunciation and prescription—are valid and warrant reversal of the lower court’s decision.

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Ruling:

• (Subscriber-Only)

Ratio:

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Doctrine:

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