Facts:

The case involves Maria Balais and Petronilo Eraya, who are the petitioners and successors in interest of Juan Balais and Juancho Balais, against respondents Buenaventura, Adela, Rosita, and Teresita, all surnamed Balais. The events leading to this case began on April 22, 1964, when the Balais siblings filed a complaint against Petronilo Eraya in the Court of First Instance (CFI) of Leyte, seeking recovery of real property and damages, which was docketed as Civil Case No. 811. On August 5, 1965, the lower court ruled in favor of the plaintiffs, declaring a sale of a portion of land to Eraya null and void and ordering him to convey half of the property back to the plaintiffs, while also adjudicating shares of the estate to the deceased Escolastico Balais's legitimate and illegitimate children.

Subsequently, on March 28, 1966, the court issued a writ of execution for the decision. However, Eraya filed a motion to set aside this order, which was denied on June 27, 1966. I...

Facts:

Background of the Case

• The petitioners, Maria Balais and Petronilo Eraya (successors in interest of Juan Balais and Juancho Balais), initially filed a case for the recovery of real property and damages.
• The case was instituted in the Court of First Instance of Leyte under Civil Case No. 811.
• The controversy arose over the title to real property and, although the complaint was for reconveyance, the lower court proceeded to distribute the hereditary estate of the late Escolastico Balais.

Chronology and Judicial Proceedings

• April 22, 1964 – A complaint was filed by Juan, Maria, Buenaventura, Adela, Rosita, and Teresa Balais against Petronilo Eraya for recovery of real property and damages.
• August 5, 1965 – The lower court rendered its decision in Civil Case No. 811:
• It declared a sale of a portion of the parcel null and void and ordered a deed of conveyance within thirty days.
• It provided for the distribution of the deceased Escolastico Balais’s hereditary estate, dividing one-half of the estate among the legitimate heirs (Juan and Maria Balais) and assigning a one-fourth share to the illegitimate children (Buenaventura, Adela, Rosita, and Teresa Balais), with corresponding provisions for the widow, Eutelia Masalig.
• It ordered the defendant to render an accounting and to pay litigation expenses and attorney’s fees.
• March 28, 1966 – An order was issued for the issuance of a writ of execution of the lower court’s decision.
• May 12, 1966 – Defendant Petronilo Eraya filed a motion to set aside the writ of execution, which was subsequently denied on June 27, 1966.
• February 23, 1967 – Maria and Juan Balais, along with Petronilo Eraya, filed a complaint (Civil Case No. C-893) seeking the annulment of the portion of the judgment that awarded a one-fourth share of the estate to the illegitimate children.
• March 10, 1967 – The answer with counterclaim was filed by the illegitimate children and their co-defendants; the parties agreed to submit the case for decision based solely on pleadings and existing documentary evidence.
• July 29, 1967 – The trial court rendered a decision dismissing the complaint for annulment.

Controversial Points Raised

• The petitioners questioned whether the trial court had the jurisdiction to decree a partition in an action initially filed merely for reconveyance of property, considering that the complaint did not specifically allege a partition of the estate.
• They contended that it was improper for the court to apply provisions of the new Civil Code — particularly Articles 887 and 895 — in determining the successionary rights involving the estate of a decedent who died in 1946 (under the old Civil Code regime), thereby awarding rights to illegitimate children.

Certification by the Court of Appeals and Appeal Issues

• The Court of Appeals certified the case to the Supreme Court on the ground that the questions involved were purely of law.
• The specific questions put forward were:
• Does the court have jurisdiction to decree a partition in an action for reconveyance?
• May the provisions of the new Civil Code be applied to determine successionary rights of heirs when the decedent died under the old Civil Code?
• The appellate review was invoked under Section 17 of the Judiciary Act of 1948, which grants the Supreme Court jurisdiction over cases involving questions of law and jurisdiction.

Issue:

Jurisdiction to Decree Partition

• Whether the trial court, although the original complaint was for reconveyance and not partition, nevertheless acquired jurisdiction to order the partition and distribution of the estate.
• Whether the subsequent introduction of claims and issues not originally pleaded could be adjudicated by the court based on the acquiescence of the parties and the doctrine of amendment of pleadings.

Retroactive Application of the New Civil Code

• Whether the application of Articles 887 and 895 of the new Civil Code was proper in awarding a one-fourth share of the estate to the illegitimate children, considering the decedent died in 1946 under the old Civil Code which did not grant successionary rights to such children.
• Whether the new rights, being declared for the first time, could have retroactive effect without impairing the vested rights of parties such as Maria Uson, whose ownership became vested in 1945.

Estoppel and Acceptance of Jurisdiction

• Whether the petitioners, by accepting certain portions of the judgment and not contesting others, effectively estopped themselves from challenging the trial court’s jurisdiction over the partition issue.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)