G.R. No. 161955 - Moldes vs. Villanueva

The original owners of the property were Juan Mollet and Silvina Del Monte, spouses who owned three parcels of land (Lot Nos. 589, 590, and 591) totaling 3,600 square meters in the Municipality of Taguig (now part of Muntinlupa City), evidenced by TCT No. 2180.
The family tree involved multiple generations:

Their daughter Josefa (who died intestate at age 25) left no issue.
Juan Mollet died intestate in 1934 and his widow in 1948, leaving a surviving daughter, Romana Mollet, who married Andres Gelardo.
Romana and Andres had five children (Flaviana, Brigida, Maria, Isaac, and Leonila), all bearing the surname Gelardo.
Subsequent marriages and children resulted in various branches with surnames Villanueva, Maritana, Dullavin, Tolentino, and Malacca, making the genealogical and inheritance interests complex.

On March 17, 1965, a Deed of Extrajudicial Settlement with Quitclaim was executed covering the three lots, involving several family members from both the Mollet/Gelardo lineage and the Moldes families as signatories.
The partition details were as follows:

Lot 589: Divided among Maria Gelardo (A14 share) and the Moldes siblings (Emeterio, Domingo, Celedonio, Rosita, and Carolina Cedia) with an A12 share; it appears that some Villanueva siblings waived their A14 share in favor of the Moldeses and Carolina.
Lot 590: Subdivided into various parts (590-B, 590-C, and 590-D), with waivers and reallocations among Leonila Gelardo, Maria Gelardo, Mariano Dullavin, and the Moldes parties.
Lot 591: Partitioned with an A34 share allocated to Leonila Gelardo, an A14 share to Maria Gelardo, and Lots 591-B and 591-C to Celedonio Moldes; further waivers by various parties rendered certain shares null.

Several heirs—particularly from the Villanueva and Dullavin branches—alleged that they were deceived into signing the deed:

Plaintiffs claimed that, due to their illiteracy and young age at the time, they did not fully understand the nature and full legal consequences of the document.
They alleged fraud and undue influence on the part of Leonila Gelardo and Celedonio Moldes, asserting that they were hoodwinked into signing waivers of their rightful inheritance.

The deed was further questioned as being void due to the inclusion of parties (specifically certain Moldeses) who were not actual heirs of the spouses Mollet, thus tainting the partition.

On January 26, 1987, Manuel Villanueva (and his children Tiburio and Apolonio) along with Mariano Dullavin (and his children Rolando and Teodora) filed a complaint before the RTC of Makati seeking the annulment of the deed, along with claims for moral and exemplary damages, attorney’s fees, and costs.
The RTC, on May 16, 1994, ruled that the deed was void as the consent of the plaintiffs was vitiated by fraud and that the deed was a sham. It ordered rescission of the deed, partition of the estate among the true heirs, and awarded damages.
The defendants appealed the decision to the Court of Appeals (CA), arguing errors in establishing heirship, in voiding the deed on grounds of fraud, and in the award of damages.
On January 30, 2003, the CA affirmed with modification the RTC decision by upholding the void nature of the deed but deleted the award of damages and attorney’s fees.
The petition for review on certiorari was ultimately raised to the Supreme Court, challenging the appellate court’s decision and its evidentiary and procedural evaluations.

Whether the Deed of Extrajudicial Settlement with Quitclaim is null and void due to fraud, undue influence, and the lack of proper consent by the signatories.
Whether the inclusion of non-heirs (specifically certain Moldes) in the deed affected the validity of the partition of the property.

Whether the respondents, acting as plaintiffs in the original complaint, failed to implead all the indispensable parties required for a complete and final adjudication of the estate’s partition.
The impact of the absence of heirs such as those from Juanita Maritana and other family members, and signatories like Emeterio and Domingo Moldes, on the court’s ability to reach a conclusive determination.

Whether the illiteracy and vulnerability of the plaintiffs contributed to an unconsciously made waiver of their rights and thus, constituted sufficient grounds for declaring the deed void.
How the representation by the parties—particularly the role of Leonila Gelardo—misled the plaintiffs into signing a document with grave legal consequences.

Whether the action seeking annulment of the deed prescribed, given that more than 20 years had elapsed from the execution of the deed.