Case Digest (G.R. No. 136466)
Facts:
In Oscar Constantino, Maxima Constantino and Casimira Maturingan v. Heirs of Constantino, the petitioners are grandchildren of the late Pedro Constantino, Sr., who died owning an unregistered 240-sqm parcel of land in Sta. Monica, Hagonoy, Bulacan (Tax Declaration No. 20814). He was survived by six children: Pedro Jr., Antonia (died without issue), Clara (died without issue), Bruno (survived by six children including Casimira), Eduardo (survived by daughter Maura), and Santiago (survived by five children including Oscar). On June 17, 1999, respondents Asuncion Laquindanum and Josefina Cailipan, great-grandchildren of Pedro Sr. representing the heirs of Pedro Jr., filed a complaint seeking nullification of a purported Pagmamana sa Labas ng Hukuman dated August 10, 1992, and related tax declarations (Nos. 96-10022-02653 and 02655), alleging simulation and misrepresentation and praying for reinstatement of Tax Declaration No. 20814. The petitioners countered that the 1992 documentCase Digest (G.R. No. 136466)
Facts:
- Original Ownership and Heirs
- Pedro Constantino, Sr. (Pedro Sr.) owned several parcels of land, including:
- An unregistered 240 sq m parcel at Sta. Monica, Hagonoy, Bulacan, declared under Tax Declaration No. 20814.
- A 192 sq m parcel at the same location, formerly under Tax Declaration No. 9534.
- An agricultural lot of approximately 4 hectares.
- At his death, Pedro Sr. was survived by six children:
- Transactions Affecting the 240 sq m Lot
- On August 10, 1992, petitioners executed a document denominated “Pagmamana sa Labas ng Hukuman,” allegedly representing themselves as sole heirs of Pedro Sr., and caused new tax declarations:
- Tax Declaration No. 96-10022-02653 for Oscar (120 sq m).
- Tax Declaration No. 96-10022-02655 for Casimira (120 sq m, after conveyance from Maxima).
- Respondents Asuncion Laquindanum and Josefina Cailipan, great-grandchildren of Pedro Sr., learned in October 1998 that Tax Declaration No. 20814 was cancelled and Tax Declaration No. 02010-2170-33235 was issued in petitioners’ names.
- Judicial Proceedings
- Complaint for nullity filed on June 17, 1999, seeking:
- Declaration of nullity of the 1992 Pagmamana.
- Annulment of Tax Declarations Nos. 96-10022-02653 & 96-10022-02655.
- Reinstatement of Tax Declaration No. 20814.
- Petitioners’ counterclaim:
- Cited a 1968 Deed of Extrajudicial Settlement with Waiver adjudicating the 192 sq m lot to heirs of Pedro Jr., excluding other heirs.
- Alleged respondents’ waiver of share in other properties in exchange for the 192 sq m lot.
- Pre-trial (Aug. 15, 2000): Parties stipulated that the 192 sq m lot (Tax Dec. No. 9534) belonged to Pedro Sr. and was transferred to Maria Constantino (respondents’ predecessor).
- RTC Decision (Oct. 27, 2003): Found petitioners and respondents in pari delicto; upheld the 1992 Pagmamana and tax declarations; dismissed complaints and counterclaims.
- CA Decision (May 31, 2007): Reversed RTC; held the 1968 extrajudicial settlement concerned Pedro Jr.’s property (due to typographical error) and declared the 1992 Pagmamana void.
- Present Petition
- Petitioners sought review under Rule 45, arguing:
- The CA erred in disregarding misrepresentations in both deeds.
- The in pari delicto doctrine based on pre-trial admissions was proper but ignored.
Issues:
- Whether the Court of Appeals correctly declined to apply the in pari delicto doctrine to the competing deeds.
- Whether the 1968 Deed of Extrajudicial Settlement with Waiver pertains to Pedro Jr.’s estate or forms part of Pedro Sr.’s estate.
- Whether respondents are bound by their pre-trial admissions regarding the 192 sq m lot.
- Whether the 1992 Pagmamana and the 1968 extrajudicial settlement are void for excluding rightful heirs and violating legitime provisions.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)