G.R. No. 121157 - Heirs of Maningding vs. Court of Appeals

Petitioners: Heirs of Segunda Maningding, represented by Delfin, Gil, Emma, Manuel, Racquel, Ester, Remedios, and Jessie Parayno, together with Maxima, Leonardo, and Felicisima Parayno.
Respondents: The heirs and co-defendants of the deceased Roque Bauzon – Luis and Eriberta Bauzon (with Eriberta represented by her husband Placido Zulueta) – and Jose Parayno.
Subject Matter: Two parcels of unregistered lands in Calasiao, Pangasinan; one designated as a riceland and the other as a sugarland.

Assert that they, in common with the private respondents, owned the subject lots in common and pro-indiviso.
Allege that Roque Bauzon, one of the heirs of Ramon Bauzon y Untalan (who died intestate in 1948), repudiated the co-ownership over the sugarland in 1965 and adjudicated it solely to himself.
Claim that Juan and Maria Maningding renounced and quitclaimed their shares over the riceland in 1970 through an Affidavit of Quitclaim and Renunciation.

Insist that the Affidavit of Quitclaim and Renunciation was executed not only by Juan and Maria but also by Segunda Maningding.
Deny any execution of the Affidavit of Self-Adjudication relating to the sugarland by Roque Bauzon.

Roque Bauzon allegedly transferred the riceland to his son, Luis Bauzon, and the sugarland to his daughter, Eriberta Bauzon, through deeds of sale.

Following the death of Segunda Maningding on 31 July 1979, her heirs purportedly discovered these transfers only in 1986.
Consequently, the petitioners initiated an action for annulment of documents, accounting, and partition of the properties.

Determined that the lots formed part of the estate of Ramon Bauzon and his wife, Sotera Zulueta, devolving by right of succession in equal pro-indiviso shares to Segundo, Maria, Juan Maningding, and Roque Bauzon.
Awarded both parcels to Segunda Maningding and Roque Bauzon in equal shares based on the execution of the Affidavit of Quitclaim and Renunciation by Juan and Maria Maningding.
Rejected the deed of donation for failure to prove proper execution and authenticity, thereby nullifying the subsequent deeds of sale in favor of Luis and Eriberta Bauzon.

Initially held that the properties belonged to Roque Bauzon by the donation propter nuptias but later declared such donation void due to noncompliance with Article 633 of the old Civil Code (requiring a public instrument).
Nevertheless maintained that Roque Bauzon acquired the subject properties by acquisitive prescription, based on his open, continuous, notorious, adverse, and actual possession.

Whether the deed of donation propter nuptias executed by Roque Bauzon was valid considering the requisite formalities (i.e., being in a public instrument) as required by the old Civil Code.
Whether the Affidavit of Quitclaim and Renunciation, executed by some of the heirs, effectively negated the donation or operated as a bar to the petitioners’ claim.

Whether Roque Bauzon’s continuous, adverse, public, and uninterrupted possession of the disputed properties for the requisite period (over 30 years) qualifies as extraordinary acquisitive prescription.
Whether the acts of ownership and possession exhibited (cultivation, tilling, appropriation of produce) satisfy the elements required for prescription.

Whether the petitioners, as co-heirs who did not possess or actively enforce their rights within the statutory period, are barred from claiming a share in the properties by partition or from an accounting of produce.
Whether mere inaction or failure to explicitly repudiate co-ownership constitutes sufficient notice or waiver of their rights to oppose the adverse possession claim.