G.R. No. 8765 - Dimagiba vs. Dimagiba

Pedro Dimagiba, as the judicial administrator of the estate of the deceased Veronica Tapang, initiated a suit against Anselmo Dimagiba, the judicial administrator of the estate of the deceased Teodoro Dimagiba.
The dispute centered on whether the property that belonged to Veronica Tapang remained undivided among her lawful heirs or had been converted into the exclusive possession of Teodoro Dimagiba and, subsequently, his heirs.

Veronica Tapang died intestate on April 6, 1883; intestate proceedings were initiated on April 8, 1883, in the Court of First Instance of Bulacan.
An inventory was executed, detailing the real and personal property of the decedent. It included adjustments regarding certain parcels of land, debts owed by third parties, and the identification of property under litigation.
By a decree dated July 17, 1886, the heirs of Veronica Tapang were declared, including her son Teodoro Dimagiba, grandchildren from different branches of the family, and other persons potentially having a claim.
Although expert appraisers and accountants were appointed to value and partition the estate, there is no conclusive record that the partition was ever finalized.

On April 21, 1911, a written complaint was filed by counsel for Pedro Dimagiba alleging that the property in dispute was erroneously considered exclusively as belonging to Teodoro Dimagiba.
The complaint sought that Anselmo Dimagiba, as the current administrator, account for and restore the property to the intestate estate of Veronica Tapang for distribution among her heirs.
Defendant (Anselmo Dimagiba) responded by denying the allegations, arguing that the property in question was solely that of Teodoro Dimagiba and had already been partitioned among the heirs, to the extent that some of it had been sold.
The record shows that before the present appeals, the case had been tried twice: a judgment on April 13, 1912, which was later modified by a remand for a new trial pursuant to an August 5, 1913 resolution, and a subsequent judgment rendered on January 31, 1915.

Documents (Exhibits 1, 2, and 3) – certified possessory information titles allegedly establishing possession by the predecessor in interest, Teodoro Dimagiba.
Proceedings records from the intestate inventory which identified the property in question with the participation of all interested parties.

Witness testimonies, particularly those by local residents, affirmed that Teodoro Dimagiba had managed and continuously possessed the property during and after the lifetime of Veronica Tapang, suggesting a de facto undivided condition among the coheirs.

The main question was whether the property personally belonging to Veronica Tapang had been partitioned among her heirs or whether it remained undivided, remaining improperly in the hands of Teodoro Dimagiba and his successors.
The challenge also focused on whether the possession exercised by Teodoro Dimagiba (and later by his heirs) could be recognized as title or whether it was merely a co-heir possession that necessitated subsequent judicial partition for proper distribution.

Does the long-standing possession and management of the property by Teodoro Dimagiba correspond to an acquisition of exclusive ownership rights?
Can possession by a coheir, acting as administrator, effectuate a title that precludes the other heirs from claiming their share?

Are the three certified copies of possessory information titles adequate proof of exclusive title or ownership by Teodoro Dimagiba and his successors?
How does the inventory record from the intestate proceedings factor into affirming the undivided nature of the property?

Is an action for the recovery of possession appropriate, or should the matter be resolved through partition proceedings as prescribed by law?
How does Article 1965 of the Civil Code, which excludes prescription among coheirs, affect the claim of exclusive possession by the defendant?

Must the judicial administrator of Teodoro Dimagiba’s estate render a full accounting and restore the property to Veronica Tapang’s intestate estate for proper distribution?
Do the proven facts necessitate immediate judicial intervention to secure the estate for all legitimate heirs?