G.R. No. 112954 - Distajo vs. Court of Appeals

Iluminada Abiertas was the owner of seven parcels of land identified as Lot Nos. 1001, 1018, 1046, 1047, 1048, 1049, and 1057 located in Capiz.
During her lifetime, Iluminada Abiertas appointed her son, Rufo Distajo, as the administrator of the properties under her control.
The transactions revolve around sales and certifications of sale executed by Iluminada Abiertas regarding different portions of her properties.
Justo Abiertas, Jr., the brother of Iluminada Abiertas, died leaving behind his children who later disposed of certain parcels of land originally inherited from him.

On May 21, 1954, Iluminada Abiertas sold a portion (designated as Lot No. 1018-A) of Lot No. 1018 to her other children: Raul, Ricardo, Ernesto, Federico, and Eduardo Distajo.
On May 29, 1963, she certified the sale of Lot Nos. 1046 and 1047 in favor of Rufo Distajo.
On June 4, 1969, she sold Lot No. 1057 to Rhodora Distajo, who is Rufo Distajo’s daughter.
On July 12, 1969, Iluminada Abiertas executed the sale of Lot No. 1018 to Rufo Distajo.
After the death of Justo Abiertas, Jr., his daughter Teresita, among other heirs (Alicia, Josefa, and Luis Abiertas), handled the properties she inherited – namely Lot Nos. 1001, 1048, 1049, and a portion of Lot No. 1047.
On May 26, 1954, Teresita Abiertas sold Lot No. 1001 to Rufo Distajo.
On June 2, 1965, acting on behalf of herself and her siblings, Teresita sold Lot Nos. 1048, 1049, and a portion of Lot No. 1047 to Rufo Distajo.

Rufo Distajo, upon purchasing the parcels, took possession of the properties and paid the corresponding real estate taxes.
Rhodora Distajo likewise paid real estate taxes for Lot No. 1057.
Upon the death of Iluminada Abiertas in 1971, certain heirs (including Zacarias Distajo, Pilar Distajo-Tapar, and Rizaldo Distajo) demanded possession of the seven parcels from Lagrimas S. Distajo and her husband, Rufo Distajo, who refused such demand.

On June 5, 1986, Ricardo Distajo, with other heirs of Iluminada Abiertas, filed a complaint in the Regional Trial Court, Roxas City, seeking recovery of possession, ownership of Lot No. 1018, partition of various lots (including parts of Lots 1001, 1018, 1046, 1047, 1048, 1049, and 1057), and damages.
Lagrimas Distajo filed an answer with a counterclaim on September 4, 1986.
The trial court dismissed both the complaint and the counterclaim on April 9, 1990, citing lack of cause of action, laches, and prescription.
Both parties appealed; the Court of Appeals rendered a decision on August 21, 1992, modifying the trial court’s ruling by partitioning Lot No. 1018 into two parts and directing subsequent administrative actions regarding tax declarations.
A motion for reconsideration was filed by Ricardo Distajo on September 10, 1992, but was eventually denied on December 9, 1993, leading to the present petition for review.

Petitioner asserts that Iluminada Abiertas exclusively owned the seven parcels, which rightfully should be partitioned among all her heirs.
It is alleged that Rufo Distajo, by virtue of being the administrator, is prohibited under the Civil Code from acquiring properties under his administration.
The petitioner contends that Rufo Distajo engaged in fraudulent acts, including possibly forging Iluminada Abiertas’ signature on various deeds of sale to effect the transactions.
In contrast, Lagrimas S. Distajo defended that the transactions were valid based on the deeds of sale and certification provided by Iluminada Abiertas, noting that even the properties inherited by Justo Abiertas, Jr.’s heirs were sold to Rufo Distajo.

Whether the sale transactions executed by Rufo Distajo, in his capacity as administrator, were valid given the Civil Code’s prohibition on agents or administrators acquiring properties under their administration.
Whether the explicit consent of the principal (Iluminada Abiertas) removed the transaction from the scope of the prohibition in Article 1491 of the Civil Code.

Whether the signatures of Iluminada Abiertas on the various deeds of sale are genuine or forged, particularly in the transactions involving Lot Nos. 1018, 1046, 1047, and 1057.
Whether the petitioner provided clear and convincing evidence, including forensic testimony, to substantiate the claim of forgery.

Whether the partitioning of Lot No. 1018 as ordered by the Court of Appeals, dividing it into Lot 1018-A and 1018-B, appropriately reflects the respective ownership and rights of the parties.
Whether the appellate decision adequately considered the factual findings regarding the payment of taxes and possession of the properties.