Title
Bagayas vs. Bagayas
Case
G.R. No. 187308
Decision Date
Sep 18, 2013
Petitioner sought annulment of sale and partition, alleging falsified deed post-adoptive mother's death. RTC dismissed, citing collateral attack on title. SC upheld dismissal, ruling proper remedy is intestate proceedings for estate settlement.
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Case Digest (G.R. No. 187308)

Facts:

Background of the Case

  • Hilaria Bagayas (petitioner) filed a complaint for annulment of sale and partition before the Regional Trial Court (RTC) of Camiling, Tarlac, on June 28, 2004, docketed as Civil Case No. 04-42.
  • She claimed that respondents (Rogelio, Felicidad, Rosalina, Michael, and Mariel Bagayas) intended to exclude her from inheriting from the estate of her adoptive parents, Maximino Bagayas and Eligia Clemente, by falsifying a deed of absolute sale dated October 7, 1974, transferring two parcels of land to respondents Rogelio and Orlando Bagayas.

Allegations of Falsification

  • The deed of absolute sale bore the signature of Eligia, who had died on August 21, 1971, making it impossible for her to have signed the document.
  • Despite this, the Bagayas brothers secured Transfer Certificate of Title (TCT) Nos. 375657 and 375658 over the subject lands.

Trial Proceedings

  • Petitioner presented herself and five other witnesses to prove her allegations.
  • Respondents denied knowledge of petitioner’s adoption and claimed that petitioner had not lived with the family.
  • Rogelio Bagayas testified that after their parents’ death, he and Orlando executed a Deed of Extrajudicial Succession to transfer the titles to their names. However, they discovered a deed of absolute sale in their father’s old files, which they used for convenience.

RTC Decision in Civil Case No. 04-42

  • The RTC dismissed the case on March 24, 2008, ruling that:
    1. Petitioner was indeed the adopted child of Maximino and Eligia.
    2. The deed of absolute sale was valid because the subject lands belonged exclusively to Maximino, and Eligia’s signature was a surplusage.
    3. Petitioner could not ask for partition of the subject lands as she failed to prove any grounds to invalidate the deed of absolute sale.
    4. The action for annulment of sale was improper as it constituted a collateral attack on the title of Rogelio and Orlando.

Motion for Reconsideration

  • Petitioner filed a motion for reconsideration, arguing that the subject lands were conjugal properties of Maximino and Eligia.
  • The RTC admitted it erred in declaring the lands as Maximino’s exclusive property but upheld the dismissal, reiterating that the action was a collateral attack on the title.

Subsequent Petitions (LRC Nos. 08-34 and 08-35)

  • On August 1, 2008, petitioner filed twin petitions under Section 108 of Presidential Decree No. 1529 (Property Registration Decree) to amend TCT Nos. 375657 and 375658 to include her name and her heirs as co-owners.
  • The RTC dismissed these petitions on the ground of res judicata, ruling that the causes of action were similar to the earlier dismissed case.

Issue:

  1. Whether the dismissal of Civil Case No. 04-42 on the ground of collateral attack on the certificates of title bars a subsequent petition under Section 108 of PD 1529.
  2. Whether the dismissal of LRC Nos. 08-34 and 08-35 on the ground of res judicata was proper.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Conclusion:

The Supreme Court upheld the dismissal of petitioner’s petitions, emphasizing that the proper remedy is to file intestate proceedings for the settlement of the estate of her adoptive parents.


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