Facts:

The case revolves around a parcel of land designated as Lot No. 4277, measuring 5,327 square meters, located in Lapu-Lapu City, originally registered under Original Certificate of Title (OCT) No. RO-3456 in the names of spouses Sixto Silawan and Marcosa Igoy. They had one child, Roberta Silawan, who is one of the petitioners. On July 16, 2002, Antonio Carlota Dy filed a complaint against the petitioners—Nicomedes Augusto, Gomercindo Jimenez, Marcelino Paquibot, and Roberta—along with the Register of Deeds of Lapu-Lapu City. Antonio claimed ownership of a portion of Lot No. 4277 based on a purchase made on November 25, 1989. He traced the ownership back to a series of transactions starting from a sale by Sixto to Severino Silawan on March 31, 1965. The property was subsequently sold through various transactions, ultimately leading to Antonio's claim.

In January 2002, while attempting to secure a certificate of title, Antonio discovered that Transfer Certificates of Title...

Facts:

Background of the Property and Original Ownership

• The subject matter is Lot No. 4277, a parcel of land measuring 5,327 square meters (sq m) located in Lapu-Lapu City.
• The land was originally registered in the names of spouses Sixto Silawan and Marcosa Igoy under Original Certificate of Title (OCT) No. RO-3456.
• Sixto and Marcosa had one child, Roberta Silawan, who later became central to the dispute.

Chain of Transfers and Transactions

• The chain of conveyances began when, on March 31, 1965, Sixto sold Lot No. 4277 to Severino Silawan.
• On May 7, 1965, Severino sold one-half of the property (2,663.5 sq m) to Isnani Maut and Lily Silawan.
• On September 16, 1966, Isnani and Lily transferred the 2,663.5 sq m to Filomeno Augusto and Lourdes Igot.
• On November 25, 1989, Filomeno and Lourdes sold a 2,363-sq m portion to Antonio Carlota Dy; the remaining 300 sq m was sold to Nicomedes Augusto and Gaudencia Augusto.
• Subsequent transactions led to the issuance of four Transfer Certificates of Title (TCTs) on December 14, 2001, replacing the original OCT. These TCTs divided the property as follows:
• Lot No. 4277-A (300 sq m) for spouses Nicomedes Augusto and Gaudencia Augusto.
• Lot No. 4277-B (1,331 sq m) for Gomercindo Jimenez and Estela Jimenez.
• Lot No. 4277-C (1,332.50 sq m) for Marcelino Paquibot and Elena Paquibot.
• Lot No. 4277-D (2,363.50 sq m) for Roberta Silawan.

Extrajudicial Settlement and Subsequent Controversy

• On June 27, 2001, Roberta executed a document titled “Extrajudicial Settlement by Sole and Only Heir with Confirmation of the Deed of Absolute Sale(s)” wherein she:
• Declared herself as the only heir of Sixto and Marcosa.
• Adjudicated the entire Lot No. 4277 to herself and confirmed the previous conveyances executed by her father.
• The document was duly annotated in OCT No. RO-3456 on December 14, 2001, paving the way for the TCT issuances.
• Respondent Antonio (Antonio Carlota Dy) later filed a Complaint for Declaration of Nullity of the deeds and partition pursuant to his claim that he acquired his share from a purchase on November 25, 1989 and that subsequent transfers were tainted by irregularity.
• In parallel, respondent Mario Dy asserted his ownership over another portion of Lot No. 4277 through a separate chain of transfers originating in 1965, involving sales by severino to Mariano Silawan and subsequent transactions.

Pretrial Proceedings and Default

• During the pretrial, petitioners (Nicomedes, Gomercindo, Marcelino, and Roberta) failed to appear without a valid excuse.
• Their absence led the RTC to declare them in default and allow respondent Antonio to present his evidence ex parte.
• Petitioners later argued that the non-appearance was due to their counsel’s lost calendar, but this excuse was found insufficient.

Trial Court (RTC) Decision

• On November 9, 2012, the RTC rendered a Decision granting Antonio’s complaint.
• The RTC declared void a series of documents, including:
• The Extrajudicial Settlement executed by Roberta.
• The Affidavit of Loss by Marcelino.
• The petitioners’ Letter-Request to cancel OCT No. RO-3456.
• The Deed of Partition executed by petitioners.
• The Deed of Sale between Mariano and Consorcia in favor of Marcelino.
• As a remedy, the RTC ordered the cancellation of all TCTs issued to the petitioners and mandated a new partition of the property, allocating specific lot areas to:
• Spouses Antonio and Jean Dy.
• Spouses Mario and Luisa Dy.
• Spouses Gomercindo and Estela Jimenez.
• Spouses Nicomedes and Gaudencia Augusto.

Court of Appeals (CA) and Petitions for Reconsideration

• On November 20, 2014, the CA affirmed in toto the RTC’s ruling, reasoning that Roberta could not unilaterally reverse the sales made by her father.
• The CA held that the extrajudicial settlement lacked probative value, and all accompanying documents were tainted by fraud.
• Petitioners filed a Motion for Reconsideration, which was denied on June 2, 2015.
• The petition to the Supreme Court raised two primary issues:
• The propriety of declaring petitioners in default and allowing ex parte presentation of evidence by respondents.
• The propriety of the cancellation of the petitioners’ TCTs arising from the disputed extrajudicial settlement and subsequent partition.

Issue:

Propriety of the Pretrial Default and Ex Parte Presentation

• Whether the RTC’s declaration of default due to the non-appearance of petitioners at the pretrial conference was justified.
• Whether allowing respondents to present evidence ex parte was proper under Rule 18, Section 5 of the 1997 Rules of Court.

Validity and Effects of the Extrajudicial Settlement

• Whether Roberta’s execution of the Extrajudicial Settlement, which adjudicated to herself the whole of Lot No. 4277 and confirmed earlier sales, was valid.
• Whether such a settlement could later be used to ratify transfers that affected the rights of other co-owners.

Validity of Subsequent Conveyances and Partition

• Whether the sales and transfers subsequent to the original sale by Sixto—specifically, those to Filomeno (in favor of Antonio and Nicomedes) versus those involving Mariano’s conveyances (to Marcelino, Rodulfo, and Mario Dy)—are valid.
• Whether petitioners’ TCTs, issued based on documents tainted by irregularity, should be cancelled and replaced by new titles reflecting the rightful partition of the property.

Ruling:

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Ratio:

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Doctrine:

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