G.R. No. 223099 - People vs. Alejandro y Pimentel

Simon Velasco (deceased) owned several properties including the subject property covered by Original Certificate of Title (OCT) No. 20630, located in Namantao, Daraga, Albay.
Simon had four children: Heriberto Velasco, Genoviva Velasco, Felisa Velasco, and Juan Velasco.
Respondents Felix Luna, Jr., Armando Velasco, and Antonio Velasco, heirs of Genoviva and Heriberto, claimed ownership rights.
Petitioners Lilibeth Espinas-Lanuza and Onel Espinas, heirs of Leopoldo Espinas (son of Felisa), also claimed ownership.

Respondents alleged that Juan and Felisa, through deceit and misrepresentation, executed a Deed of Extrajudicial Settlement and Sale dated May 14, 1966, transferring the subject property to Leopoldo without the consent or knowledge of the other heirs.
Respondents discovered this alleged fraud in 2010 when they learned that Tax Declaration No. 02-040-0147 was registered under Leopoldo's name.
Petitioners argued that Simon died intestate but that his children orally partitioned the estate, distributing specific properties to each heir: Magogon, Camalig to Genoviva; Ting-ting, Taloto, Camalig to Heriberto; and the subject property as the joint share of Juan and Felisa, who then validly transferred their shares to Leopoldo.
Petitioners maintained that the oral partition was recognized through possession, taxation declarations, and lack of contestation from other heirs over decades.

The Regional Trial Court (RTC), Legazpi City, Branch 1, ruled in favor of respondents, declaring that the subject property remained co-owned by all heirs, dismissing petitioners’ claims to exclusive ownership based on the extrajudicial settlement and sale.
The Court of Appeals (CA) affirmed the RTC, emphasizing that an extrajudicial settlement without the participation or notice of certain heirs was void, and that the deed transferring the property was executed without Heriberto and Genoviva’s consent, rendering it fraudulent.
Petitioners moved for reconsideration with the CA, which was denied.
Petitioners then filed the present petition for review on certiorari to the Supreme Court.

Whether the oral partition of Simon Velasco’s estate among his heirs, including the allocation of the subject property to Juan and Felisa, was valid and enforceable despite the absence of a written partition deed.
Whether the Deed of Extrajudicial Settlement and Sale dated May 14, 1966, executed by Juan and Felisa in favor of Leopoldo, was valid and binding on all heirs despite the non-participation of Heriberto and Genoviva.
Whether laches and the doctrine of acquiescence bar the heirs’ claims to the subject property given the delay of 44 years before asserting ownership rights.
Whether the Court of Appeals gravely abused its discretion and erred in confirming the annulment of the extrajudicial settlement and sale on grounds of fraud due to the exclusion of some heirs.