Facts:

The case involves a petition for review on certiorari filed by Gavina Maglucot-Aw and several others (petitioners) against Leopoldo Maglucot, Severo Maglucot, Wilfreda Maglucot-Alejo, and Constancio Alejo (respondents). The dispute centers around Lot No. 1639, originally covered by Original Certificate Title No. 6775, issued on August 16, 1927, to several co-owners, including Hermogenes Olis and Bartolome Maglucot. On April 19, 1952, Tomas Maglucot, a registered owner and predecessor-in-interest of the respondents, filed a petition to subdivide Lot No. 1639. The Court of First Instance (CFI) of Negros Oriental issued an order on May 13, 1952, directing the subdivision of the lot into six portions. The petitioners claim that they are the rightful owners of Lot No. 1639-D, which was part of the original lot, and that a partition had been effectively carried out.

In 1963, Guillermo Maglucot rented a portion of Lot No. 1639-D, followed by respondents who also rented portions i...

Facts:

1. Ownership and Title of Lot No. 1639

   • Lot No. 1639 was originally covered by Original Certificate of Title (OCT) No. 6775, issued on August 16, 1927, in the names of Hermogenes Olis, Bartolome Maglucot, Pascual Olis, Roberto Maglucot, Anselmo Lara, and Tomas Maglucot.

2. Petition for Subdivision

   • On April 19, 1952, Tomas Maglucot, one of the registered owners and respondents' predecessor-in-interest, filed a petition to subdivide Lot No. 1639.
   • On May 13, 1952, the Court of First Instance (CFI) of Negros Oriental issued an order directing the subdivision of Lot No. 1639 into six portions, each allocated to the respective co-owners.

3. Rental Agreements and Possession

   • In 1963, Guillermo Maglucot rented a portion of Lot No. 1639-D (the subject lot).
   • Leopoldo and Severo Maglucot also rented portions of the subject lot in 1964 and 1969, respectively, paying annual rentals to Ruperta Salma, who represented the heirs of Roberto Maglucot.
   • In December 1992, Leopoldo and Severo stopped paying rent, claiming ownership over the subject lot.

4. Filing of the Complaint

   • Petitioners filed a complaint for recovery of possession and damages, asserting ownership of Lot No. 1639-D based on the alleged partition of Lot No. 1639 in 1952.
   • Respondents, however, denied the partition and claimed co-ownership of Lot No. 1639-D.

5. RTC Decision

   • The Regional Trial Court (RTC) ruled in favor of the petitioners, finding that the tax declarations and the active participation of Tomas Maglucot in the partition proceedings were sufficient evidence of partition.
   • The RTC ordered respondents to vacate the premises, demolish their houses, and pay damages.

6. CA Decision

   • The Court of Appeals (CA) reversed the RTC decision, ruling that the sketch plan and tax declarations were not conclusive evidence of partition.
   • The CA found that the prescribed procedure under Rule 69 of the Rules of Court was not followed, and thus, no valid partition occurred.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Partition and Ratification

   • An oral partition, when followed by actual possession and acts of ownership, is valid and enforceable.
   • The parties' long-standing possession of specific portions of Lot No. 1639, in accordance with the sketch plan, ratified the partition.

2. Estoppel by Conduct

   • Respondents' payment of rentals and their tax declarations acknowledging Roberto Maglucot's ownership estopped them from claiming co-ownership.
   • A party cannot accept the benefits of a partition and later deny its validity.

3. Finality of Partition Orders

   • An order for partition is final and appealable. The 1952 order for partition, not having been appealed, became final and binding on the parties.
   • The purpose of court approval of a partition is to give effect to the subdivision plan, which was achieved through the parties' actions.

4. Improper Language in Pleadings

   • The Court admonished petitioners' counsel for improper references to the CA researcher in their pleadings, emphasizing the need for respect and professionalism in legal proceedings.

Conclusion:

The Supreme Court ruled in favor of the petitioners, holding that a valid partition of Lot No. 1639 had been effected in 1952. Respondents were estopped from denying the partition due to their long-standing possession and acknowledgment of Roberto Maglucot's ownership. The CA decision was reversed, and the RTC decision was reinstated.