Facts:

The case involves Purificacion Balilo-Montero and Jovencio Balilo as petitioners against Eugenia Septimo, Consuelo Robles, and Placido Robles as respondents. It originated from the ownership dispute over a parcel of land totaling 7.7837 hectares located in San Jose, Occidental Mindoro and covered by Homestead Patent No. 46784, issued to Jose Balilo on February 21, 1938. Jose Balilo passed away intestate on August 12, 1943. In 1948, his sister Niniana Balilo sought guardianship over Jovencio Balilo, alleged to be the son of Jose. The Court of First Instance (CFI) approved Niniana's motion to sell the land to Jose Septimo, but this deed remained unregistered. In 1963, Jovencio filed a complaint against Septimo for rescission of the sale, but the CFI dismissed this case citing the expiration of the five-year repurchase period under Commonwealth Act No. 141. Later, on March 3, 1987, Purificacion filed a possession lawsuit against Eugenia, the surviving spouse of Jose Septimo, an

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Facts:

Ownership and Patent Details

• Jose Balilo was the owner of a parcel of agricultural land measuring 7.7837 hectares located in San Jose, Occidental Mindoro.
• The property was covered by Homestead Patent No. 46784 issued on February 21, 1938, and subsequently by Original Certificate of Title (OCT) No. 3014 issued by the Register of Deeds.

Guardianship Proceedings and the Deed of Sale

• On August 12, 1943, Jose Balilo died intestate.
• Sometime in 1948, Niniana Balilo, Jose Balilo’s sister, filed a petition for guardianship of Jovencio Balilo, alleging he was her nephew and the son of the deceased. The case was docketed as Special Proceeding No. 262 in the Court of First Instance (CFI) of Pampanga.
• As guardian, Niniana sought and was granted authority to execute a deed of absolute sale over the property in favor of Jose Septimo for P750.00.
• Niniana executed the deed, and Jose Septimo subsequently declared the property in his name for taxation purposes and paid the realty taxes, though he failed to secure a Torrens title because the deed was not registered.

Subsequent Litigation Involving Jovencio Balilo

• On October 12, 1963, Jovencio Balilo filed a complaint in the CFI of Occidental Mindoro (Civil Case No. R-159) to compel Jose Septimo to resell the property to him.
• Jovencio alleged that he was the only legitimate child of Jose Balilo and Juana Villarama and prayed for an order directing the defendant to resell the property for P750.00.
• Jovencio later amended his complaint and impleaded Placido Robles, asserting that Robles had purchased a five-hectare portion of the property.
• On November 8, 1966, the CFI rendered judgment dismissing the complaint on the ground that the five-year period under Section 119 of Commonwealth Act No. 141 had elapsed.
• Jovencio did not appeal the decision.

Recovery of Possession Action by Purificacion Balilo-Montero

• On March 3, 1987, Purificacion Balilo-Montero filed a complaint with the Regional Trial Court (RTC) of San Jose, Occidental Mindoro, seeking recovery of possession of the property.
• The complaint alleged that the parties were the children and legal heirs of the late Jose Balilo. Purificacion contended that she had discovered she was one of the co-owners after the respondents claimed ownership and installed tenants on the property.
• The pleadings asserted that despite demands, the defendants (respondents) and their tenants refused to restore possession.
• In her answer, respondent Eugenia Septimo (surviving spouse of Jose Septimo) maintained that her late husband purchased the property from Jovencio via his guardian Niniana, a sale approved by the CFI in Special Proceeding No. 262. She also denied, on information sufficient only to form a belief, the allegation that she was one of Jose Balilo’s heirs.
• Consuelo Robles was declared in default for failing to answer.

Judgment and Appellate Rulings

• On October 15, 1991, the RTC rendered judgment in favor of Jovencio and Purificacion, ordering Eugenia Septimo, as successor-in-interest to decedent Jose Septimo, to reconvey one-half of the property to Purificacion Balilo-Montero.
• Eugenia Septimo appealed the decision to the Court of Appeals (CA), arguing, among other points, that Purificacion had lost her right to recover the property and that the sale executed under guardianship did not affect her share since it was unregistered.
• The CA, in its April 11, 2001 decision, applied the provisions of the Old Civil Code on testate succession and held that Jovencio inherited two-thirds and Purificacion one-third of the property. Purificacion’s motion for partial reconsideration, contending that she was entitled to an undivided one-half share under the provisions applicable to intestate succession, was denied.
• Subsequently, Purificacion Balilo-Montero filed the instant petition for review contesting the CA’s application of the law on testate succession.

Petition for Review and Final Determination

• The petitioner argued that because Jose Balilo died intestate in 1943—prior to the effectivity of the New Civil Code—the provisions of the Old Civil Code on intestate succession should apply.
• It was contended that there was no competent evidence to prove that Jose Balilo and Juana Villarama were married or cohabited as husband and wife, which would necessitate an equal division of the property between his children.
• The petitioner maintained that because of these facts, Jovencio only disposed of his one-half interest, and thus, Jose Septimo’s acquisition was limited to that undivided one-half portion.
• The Supreme Court granted the petition, reversed the Court of Appeals’ decision, set aside the erroneous allocation by the CA, and reinstated the RTC’s original judgment.

Issue:

• Whether the sale executed by Niniana Balilo in her capacity as guardian validly transferred title to Jose Septimo, and if such sale affected the property interests of the rightful heirs.
• Whether, given that Jose Balilo died intestate in 1943, the provisions of the Old Civil Code on intestate succession should govern the distribution of his property instead of the provisions on testate succession.
• Whether there is sufficient evidence to establish the marital status of Jose Balilo with Juana Villarama, and consequently, whether his children are entitled to equal shares of the inheritance.
• Whether the unregistered deed of absolute sale conferred full title over the property to Jose Septimo or only a limited interest corresponding to the portion actually owned by Jovencio Balilo.
• Whether the trial court's decision to order reconveyance of one-half of the property to Purificacion Balilo-Montero was supported by proper application of the relevant succession and property rules.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)