Title
Bernardo vs. Court of Appeals
Case
G.R. No. L-30019
Decision Date
Nov 28, 1980
Dispute over land ownership in Parañaque; Court of Appeals reversed trial court, declaring properties as community assets, upheld by Supreme Court.
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Case Digest (G.R. No. L-30019)

Facts:

Background of the Case

The case involves a dispute over the ownership and partition of three parcels of land located in San Dionisio, Parañaque, Rizal. The properties in question were allegedly owned by the spouses Miguel Bernardo and Lorenza Garcia, who had six children: Ceferino, Bonifacio, Narciso, Justo, Gregoria (alias Yoyang), and Petronila, all surnamed Bernardo.

Parties Involved

  • Petitioners: Agripina Bernardo, Constantino de Leon, and Rita Bernardo.
  • Respondents: Laureano Bernardo, Elena Bernardo, Cipriano Bernardo, Eladio de Leon y Bernardo, and Santos Bernardo.

Initial Complaint

The respondents filed an amended complaint on November 3, 1959, demanding the partition and annulment of conveyance of the three parcels of land. They claimed that the properties were community properties of the heirs of Miguel Bernardo and Lorenza Garcia.

Trial Court Decision

The trial court dismissed the complaint on June 29, 1962, ruling in favor of the petitioners. The respondents appealed to the Court of Appeals, which initially affirmed the trial court's decision on January 11, 1967.

Motion for Reconsideration

The respondents filed a motion for reconsideration, leading the Court of Appeals to reverse its original decision on August 31, 1968. The court declared the properties as community properties, with 3/5 share to the heirs of Ceferino, Bonifacio, and Narciso, and 2/5 share to the heirs of Gregoria and Justo Bernardo.

Petition for Certiorari

The petitioners filed a petition for certiorari, challenging the Court of Appeals' resolution and raising several legal questions regarding the validity of the decision.

Issue:

  1. Whether the Court of Appeals could validly declare the properties as community properties after finding that the respondents' predecessors had ceded their shares to the petitioners' father, Justo Bernardo, over 70 years ago.
  2. Whether the respondents could still demand partition of the properties after such a long period of exclusive possession by the petitioners and their predecessors.
  3. Whether the respondents could claim their predecessors' shares after the petitioners' father declared the properties in his name alone since 1906.
  4. Whether the Court of Appeals could decide the case contrary to its own findings of fact and based on unfounded assumptions.
  5. Whether a decision unanimously promulgated by a division of three Justices of the Court of Appeals could be reconsidered and set aside by a resolution promulgated almost two years later, excluding two of the original Justices.

Ruling:

The Supreme Court denied the petition for certiorari and affirmed the resolution of the Court of Appeals. The Court held that the Court of Appeals did not err in reconsidering its original decision and making new findings of fact based on a careful review of the evidence. The properties were declared community properties of the parties in the proportion determined by the Court of Appeals.

Ratio:

  1. Authority of the Court of Appeals: The Court of Appeals has the inherent power to amend and control its process and orders to conform to law and justice. It is within its authority to reconsider its decisions and make new findings of fact based on the evidence presented.
  2. Community Property: The evidence showed that the properties were originally owned by Miguel Bernardo and were community properties of his heirs. The quitclaim executed by some of the heirs in favor of Justo Bernardo did not extinguish the rights of the other heirs, as it was conditional and did not include all the heirs.
  3. Prescription and Laches: The respondents' claim was not barred by prescription or laches, as the properties were held in co-ownership, and the petitioners' possession was not in the concept of an owner to the exclusion of the other heirs.
  4. Finality of Factual Findings: The findings of fact by the Court of Appeals are generally final and conclusive, especially when supported by substantial evidence, as in this case.


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