Case Digest (G.R. No. 181508)
Facts:
OSCAR CONSTANTINO, MAXIMA CONSTANTINO AND CASIMIRA MATURINGAN, Petitioners, and the HEIRS OF CONSTANTINO, represented by LAQUINDANUM, PEDRO JR., ASUNCION, Respondents, disputed ownership of an unregistered 240 sq. m. parcel (Tax Declaration No. 20814) in Sta. Monica, Hagonoy, Bulacan, after competing instruments — a deed titled Pagmamana sa Labas ng Hukuman (10 August 1992) and an Extrajudicial Settlement with Waiver (5 December 1968) — produced separate tax declarations in favor of different descendants. The Regional Trial Court upheld the Pagmamana and related tax declarations under the doctrine of parity of fault, the Court of Appeals reversed on other grounds, and petitioners brought this Rule 45 petition to the Supreme Court.
Issues:
- Did the Court of Appeals err in refusing to apply *in pari delicto* to the competing deeds and tax declarations?
- Are the Pagmamana sa Labas ng Hukuman and the Extrajudicial Settlement with Waiver void for excluding legitimate heirs and thus inexistent under Article 1409 of the Civil Code?
- Do the parties’ pre‑trial stipulations and admissions bind the successors‑in‑interest and affect the validity of the deeds?
Ruling:
The Supreme Court REVERSED the 31 May 2007 Decision of the Court of Appeals. The Court declared the Pagmamana sa Labas ng Hukuman and the Extrajudicial Settlement with Waiver VOID and inexistent ab initio, and ordered that the estate of Pedro Constantino, Sr. be partitioned with the full participation of all his heirs.
Ratio:
The Court held that the in pari delicto principle did not apply because the case involved two separate deeds executed to exclude co‑heirs; applying the doctrine would validate both illegal instruments rather than nullify them, thereby frustrating the policy against circumvention of legitimes. Contracts whose cause or object is contrary to law and public policy are inexistent under Article 1409, and such instruments have no force or effect from the beginning. The Court also affirmed that successors‑in‑interest are privies and that judicial admissions in the pre‑trial order are binding under Section 7, Rule 18 and Section 4, Rule 129 of the Rules of Court, but those admissions did not cure the illegality of deeds that excluded rightful heirs.
Doctrine:
- Article 1409, Civil Code renders contracts inexistent and void ab initio when their object or purpose is contrary to law, morals, good customs, public order or public policy.
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