Title
Pilapil vs. Heirs of Briones
Case
G.R. No. 150175
Decision Date
Feb 5, 2007
Dispute over Maximino Briones' estate; heirs claim fraud in widow Donata’s exclusive ownership. SC ruled no fraud, claims barred by prescription and laches, upholding Donata’s sole heir status.

Case Digest (G.R. No. 150175)
Expanded Legal Reasoning Model

Facts:

  • Parties and Familial Relations
    • Petitioners: Heirs of Donata Ortiz-Briones, comprising her surviving sister Rizalina Ortiz-Aguila, niece Erlinda Pilapil, and other nephews and nieces in representation of deceased sisters.
    • Respondents: Heirs of Maximino R. Briones, consisting of his nephews, nieces, grandnephews and grandnieces in representation of his deceased siblings.
  • Intestate Proceedings of Maximino’s Estate
    • Maximino died intestate on May 1, 1952; Donata instituted Special Proceedings No. 928-R in Cebu City CFI and was appointed administratrix by Letters of Administration issued July 8, 1952.
    • Donata submitted an inventory dated October 2, 1952; by Order dated January 15, 1960 (recorded June 27, 1960), the CFI declared her the sole, absolute, and exclusive heir and transferred title to six parcels (TCT Nos. 21542, 21543, 21544, 21545, 21546, 58684) into her name.
  • Death of Donata and Subsequent Administration
    • Donata died on November 1, 1977; Erlinda Pilapil and her husband Gregorio were appointed administrators of Donata’s intestate estate.
    • A dispute arose among Donata’s heirs over three parcels allegedly donated to Erlinda by Donata via two Deeds of Donation dated September 15, 1977.
  • Proceedings for Maximino’s Estate after 1985
    • January 21, 1985: Silverio Briones (respondent) filed for Letters of Administration for Maximino’s estate; initially granted but later set aside upon motion by Gregorio Pilapil claiming prior administration by Donata and Erlinda.
    • March 3, 1987: Respondents filed Complaint for partition, annulment, and recovery of possession before RTC (Civil Case No. CEB-5794), later amended on December 11, 1992.
  • RTC, CA, and SC Decisions
    • April 8, 1986 RTC Decision: Held that heirs of Maximino were entitled to ½ of disputed properties; ordered reconveyance and accounting by Erlinda.
    • August 31, 2001 Court of Appeals: Affirmed the RTC Decision.
    • March 10, 2006 Supreme Court: Reversed CA and RTC, dismissed respondents’ complaint for lack of fraud/implied trust; SC Decision promulgated in G.R. No. 150175.
    • May–July 2006: Respondents filed Motion for Reconsideration and multiple pleadings; certified true copy of CFI Order submitted belatedly.

Issues:

  • Fraud and Implied Trust
    • Whether Donata committed fraud or misrepresentation in Special Proceedings No. 928-R justifying an implied trust under Article 1456, New Civil Code.
  • Prescriptibility of the Action
    • Whether respondents’ action to recover shares in Maximino’s estate held in implied trust is imprescriptible or barred by the ten-year prescription under Article 1144.
  • Laches
    • Whether the 33-year delay in asserting respondents’ rights amounts to laches barring relief regardless of prescription.
  • Validity of the CFI Order
    • Whether the CFI Order dated January 15, 1960 is void on its face (no jurisdiction) or merely voidable and thus not subject to collateral attack.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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