G.R. No. 79958 - Bautista vs. Grino-Aquino

Petitions were filed by Emiliana Bautista, as heir of the late Manuel Bautista, and Evangelina Bautista, against multiple respondents including Justices of the Special First Division of the Court of Appeals and judicial officers in Pasay City.
The controversy centers on the disposition of a property registered under T.C.T. No. 2210 in the name of Manuel Bautista, who inherited the property from his father, Mariano Bautista.

The subject property originally belonged exclusively to Manuel Bautista and was evidenced by its registration under T.C.T. No. 2210.
Subsequent to an extrajudicial partition executed on December 22, 1966, the title transferred to other T.C.T. numbers (T-14182, T-14186, and later T-15665 to T-15671) through various deeds of partition and sale.

A Deed of Extrajudicial Partition was executed in 1966 among the heirs of Juliana Nojadera, the first wife of Manuel Bautista, despite the fact that the property did not form part of Juliana Nojadera’s estate.
The extrajudicial partition document included the signature of Manuel Bautista, which was later examined and authenticated by the National Bureau of Investigation (NBI) on August 1, 1974.
Notably, Manuel Bautista denied having executed or agreed to the partition, which purportedly waived his rights in favor of certain private respondents.

Following the extrajudicial partition, private respondents (except Manolito Bautista) executed a Deed of Absolute Sale in favor of Manolito Bautista, leading to the issuance of a new title under T.C.T. No. T-14186.
Subsequently, on August 7, 1969, Manolito Bautista sold the property back via additional deeds of sale to the remaining private respondents, resulting in a series of title cancellations and reissuances, including T.C.T. Nos. T-15665 to T-15671.
This series of transactions indicated a systematic scheme to place the property beyond the reach of those with a lawful claim.

Manuel Bautista had married a second wife, Emiliana Tamayo, and from this marriage, had a daughter, Evangeline Bautista, born on April 29, 1949.
Petitioners contend that the extrajudicial partition, as executed, not only misappropriated property which did not belong to the estate of the deceased Juliana Nojadera but also intentionally preteritted Evangeline Bautista—a compulsory heir—thereby violating her legal rights.

In Civil Case No. 4033-P, the petitioners initially sought to nullify the extrajudicial partition, the deed of absolute sale, the subsequent transfers of title, and the associated tax declaration.
On January 14, 1983, the trial court dismissed the complaint with costs against the petitioners.
The Court of Appeals, affirming the trial court's decision on August 3, 1987, was later subject to review on the petitioners’ grounds of manifest errors in the findings and misapplication of the law concerning extrajudicial partition and succession.

Whether property belonging exclusively to the surviving husband (Manuel Bautista) may be subject to an extrajudicial partition intended for the estate of a deceased spouse (Juliana Nojadera).
Whether the inclusion of non-estate property in an extrajudicial partition violates statutory provisions, particularly given that extrajudicial settlements are confined to the decedent’s estate.

Whether the questioned Deed of Extrajudicial Partition executed on December 22, 1966, should be deemed null and void ab initio because it improperly affected property not belonging to the decedent’s estate.
Whether subsequent conveyances—namely, the deed of absolute sale and further transactions transferring titles—are rendered void by virtue of their foundation on an invalid extrajudicial partition.

Whether the partition, by effectively excluding Evangelina Bautista from her rightful share as a compulsory heir, was executed with bad faith, constituting a violation of succession laws.
Whether the petitioners’ claim to an imprescriptible right to partition co-owned property should override any contrary transactions.