Case Digest (G.R. No. 140422)
Facts:
Mercedes Cristobal Cruz, Anselmo A. Cristobal and Elisa Cristobal Sikat v. Eufrosina Cristobal, Florencio Cristobal, Jose Cristobal, Heirs of Norberto Cristobal and the Court of Appeals, G.R. No. 140422, August 07, 2006, Supreme Court First Division, Chico-Nazario, J., writing for the Court.Petitioners — Mercedes Cristobal, Anselmo A. Cristobal, the heirs of the late Socorro Cristobal, and Elisa Cristobal-Sikat — asserted that they are legitimate children of Buenaventura Cristobal by his first marriage to Ignacia Cristobal, and sought recovery of their pro indiviso shares in a 535 sq. m. lot at 194 P. Parada St., Sta. Lucia, San Juan (the subject property), which Buenaventura purchased on June 18, 1926 and in which he died intestate circa 1930. Respondents — Norberto, Florencio, Eufrosina and Jose Cristobal (children of Buenaventura by his second marriage to Donata Enriquez) — executed an extrajudicial partition in 1948 and had titles issued in their names.
Petitioners first attempted barangay conciliation in 1995 after learning that respondents had registered titles in their names, then filed a Complaint for Annulment of Title and Damages (RTC, Pasig City, Branch 156, Civil Case No. 65035) praying, among other reliefs, that the 1948 Deed of Partition be declared null and void, the respondents’ TCTs cancelled, the subject property re-partitioned according to the law of succession, and damages awarded. At trial petitioners presented baptismal certificates and witness testimony (including neighbor Ester Santos) to prove filiation and continuous possession; respondents presented birth certificates and testified to the 1948 partition and long possession and tax payments.
The trial court rendered judgment on July 11, 1997 dismissing the complaint, concluding petitioners failed to prove filiation (finding baptismal and birth certificates of scant evidentiary value) and that petitioners’ long inaction constituted laches. The Court of Appeals in CA-G.R. CV No. 56402, Decision dated July 22, 1999, affirmed the trial court (the appellate court did find fil...(Pro-only)
Issues:
- Is petitioners’ cause of action or their right to recover their hereditary shares barred by prescription?
- Is petitioners’ right to recover their hereditary shares barred by laches?
- Were petitioners able to prove their filiation with the deceased Buenaventura Cristobal?
- Is the 1948 Deed of Partition executed by respondents binding upon petitioners who did no...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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