Title
Bacani vs. Galauran
Case
G.R. No. L-16066
Decision Date
Apr 25, 1962
Natural children contest void extrajudicial partition of father’s estate; court affirms their rights, voids partition, and awards damages due to prolonged litigation.
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Case Digest (G.R. No. L-16066)

Facts:

Family Background and Property Ownership

  • Manuel Bacani, a widower, lived maritally with Monica Vargas, a widow, without the benefit of clergy. They had two children: plaintiffs Encarnacion Bacani and Virgilio Bacani.
  • Manuel Bacani acknowledged and supported the plaintiffs as his natural children. He owned Lots Nos. 1470 and 1481-D of the Cadastral Survey of Concepcion, Tarlac, covered by Original Certificate of Title No. 4499.
  • Manuel Bacani died on August 7, 1931, leaving no legitimate ascendants or descendants. His nearest relatives were his acknowledged natural children (plaintiffs), his sister Josefa Bacani, and the children of his deceased sister Candida Bacani (defendants Leonides, Paz, and Angelina Samia, collectively referred to as the Samias).

Extrajudicial Partition and Transfer of Title

  • On May 31, 1938, the Samias and Anastacia Dizon (administratrix of Josefa Bacani’s estate) executed a deed of extrajudicial partition (Exhibit A), adjudicating Manuel Bacani’s properties, including the two lots, to themselves as his alleged heirs.
  • The Court of First Instance of Pampanga approved the partition on June 23, 1938, in Special Proceeding No. 5695 (Testate Estate of Josefa Bacani). Consequently, Original Certificate of Title No. 4499 was canceled, and Transfer Certificate of Title No. 14121 was issued in favor of the Samias and Josefa Bacani’s estate on December 6, 1938.

Legal Actions by Encarnacion Bacani

  • On March 13, 1939, Encarnacion Bacani filed Special Proceeding No. 54677 in the Court of First Instance of Manila for the settlement of Manuel Bacani’s estate. She was appointed administratrix on November 6, 1939, and authorized to contest the partition.
  • On November 9, 1939, a notice of lis pendens was annotated on Transfer Certificate of Title No. 14121.
  • On January 15, 1940, Encarnacion Bacani petitioned in Special Proceeding No. 5695 to declare the extrajudicial partition null and void. The petition was denied on February 14, 1940.
  • On March 7, 1940, Encarnacion Bacani filed Civil Case No. 817 for forcible entry and unlawful detainer against the Samias. The case was dismissed on June 21, 1944, for non-appearance of the parties.
  • Before July 25, 1940, Encarnacion Bacani filed Civil Case No. 4878 to compel the Samias and Anastacia Dizon to convey the lots to her. The case was dismissed on November 26, 1943, as premature since the plaintiffs had not yet been declared heirs of Manuel Bacani.

Declaration of Heirship

  • On June 30, 1954, in Special Proceeding No. 54677, the Court of First Instance of Manila declared Encarnacion and Virgilio Bacani as the acknowledged natural children and heirs of Manuel Bacani. This decision was affirmed by the Court of Appeals on May 16, 1956 (CA-G.R. No. 13949-R).
  • On November 23, 1956, Encarnacion Bacani’s motion to compel the defendants to account for and deliver the lots was denied, prompting the filing of the present action on July 12, 1957.

Present Action

  • In Civil Case No. 3154, the plaintiffs sought: (1) declaration of ownership of the lots, (2) conveyance of the lots, (3) accounting of products, (4) payment of exemplary and moral damages, and (5) attorney’s fees.
  • The defendants moved to dismiss, arguing res judicata, statute of limitations, and lack of jurisdiction. The trial court denied the motion and ruled in favor of the plaintiffs, declaring the extrajudicial partition void and ordering the defendants to surrender the title, pay rentals, and vacate the lots.

Issue:

  1. Whether the order approving the extrajudicial partition and the dismissal of Civil Case No. 4878 constitute res judicata.
  2. Whether the plaintiffs’ cause of action is barred by the statute of limitations.
  3. Whether the trial court had jurisdiction over the subject matter.
  4. Whether the imposition of exemplary damages was justified.
  5. Whether the motion to dismiss was properly denied.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)


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