G.R. No. 194260 - Heirs of Yambao vs. Heirs of Yambao

The dispute involves a parcel of land located in Barangay Bangan, Botolan, Zambales, initially possessed by Macaria De Ocampo.
Hermogenes Yambao, Macaria’s nephew, acted as the administrator and paid taxes on the property.
Hermogenes had eight children: Ulpiano, Dominic, Teofilo, Feliciano, Asesclo, Delia, Amelia, and Melinda.
After Hermogenes died, all his heirs were allowed to access and harvest from the property, with Eleanor Yambao (Ulpiano’s daughter) building a house there.

In 2005, the heirs of Feliciano prohibited other heirs from entering the property and ejected Eleanor.
The heirs of Hermogenes filed a complaint with the RTC seeking: partition of the land, nullification of titles/documents, and damages. They alleged co-ownership of the land inherited from Hermogenes.
The heirs of Feliciano denied these allegations, claiming Feliciano possessed the land in the concept of owner since time immemorial and was awarded a free patent (Original Certificate of Title No. P-10737) in 1989.
They also argued the complaint was barred by the one-year prescription period from issuance of the free patent.

The RTC dismissed the complaint, ruling that tax declarations and receipts in Macaria’s name were inadmissible as conclusive proof of ownership.
The court found failure to prove Hermogenes had the right to succeed over Macaria’s estate.

The Court of Appeals reversed the RTC judgment, stating the RTC erred in hastily dismissing without determining co-ownership.
The CA cited evidence that Feliciano acknowledged Hermogenes’s possession since 1944, showing tacit recognition of co-ownership.
The CA ruled the RTC should have conducted partition proceedings.

The heirs of Feliciano questioned the finding of co-ownership and the order for partition, arguing it was a collateral attack on the validity of OCT No. P-10737.

Whether the parties are co-owners of the subject property inherited from Hermogenes Yambao.
Whether the heirs of Hermogenes’ action for partition is barred by prescription.
Whether the action for partition constitutes a collateral attack on the validity of the Original Certificate of Title No. P-10737.