G.R. No. 150175 - Pilapil vs. Heirs of Briones

Petitioners are the heirs of the late Donata Ortiz-Briones, composed of her surviving sister Rizalina, Rizalina’s daughter Erlinda Pilapil, and other nephews and nieces representing her other deceased sisters.
Respondents are the heirs of the late Maximino R. Briones, consisting of his nephews, nieces, and grandnephews and grandnieces, representing his deceased siblings.

Maximino was married to Donata, and their marriage produced no children.
Upon Maximino’s death on May 1, 1952, Donata initiated intestate proceedings to settle his estate before the Cebu City Court of First Instance in Special Proceedings No. 928-R.
On July 8, 1952, the Court issued Letters of Administration appointing Donata as administratrix of Maximino’s estate.

Donata submitted an inventory of Maximino’s properties, which included several parcels of land (originally covered by older Transfer Certificates of Title, later superseded by new titles).
The Court of First Instance issued an Order on October 2, 1952, awarding ownership of the real properties to Donata.
This Order was recorded in the Primary Entry Book of the Register of Deeds on June 27, 1960, whereupon new Transfer Certificates of Title (TCTs) were issued in Donata’s name.

Donata died on November 1, 1977.
A petition for the administration of her intestate estate was filed by Erlinda, and she, along with her husband Gregorio, was appointed administrator.
A controversy arose among Donata’s heirs when Erlinda claimed exclusive ownership over certain parcels of land allegedly based on two Deeds of Donation purportedly executed by Donata shortly before her death.
Despite internal disagreements among Donata’s heirs, they appeared united in defending the registration and transfer of properties that had been effected under the earlier CFI Order.

On January 21, 1985, Silverio Briones, a nephew of Maximino, filed a petition with the RTC for Letters of Administration for Maximino’s intestate estate, which was initially granted but later set aside following an opposition by Gregorio (administrator of Donata’s estate).
On March 3, 1987, the heirs of Maximino filed a Complaint before the RTC for partition, annulment, and recovery of possession of the real properties, later amended on December 11, 1992.
The Complaint alleged that through fraud and misrepresentation, Donata had secured registration of Maximino’s properties in her name, despite knowing that Maximino was survived by other legal heirs.

The RTC rendered a Decision on April 8, 1986, in favor of the heirs of Maximino.

The RTC held that Donata, though registered as the sole heir, held the properties as a trustee under an implied trust because she failed to notify or include the other heirs in the intestate proceedings.
It emphasized that no prescription could accrue against co-owners who implicitly recognize their co-ownership.

The Decision was affirmed by the Court of Appeals on August 31, 2001, which further ratiocinated that:

The proceeding for the issuance of Letters of Administration was procedurally defective with respect to the notice and inclusion of all heirs.
The remedy of partition and recovery of possession was a rightful claim of the co-heirs of Maximino.

The heirs of Donata, dissatisfied with the lower court decisions, filed the present Petition for Review on Certiorari under Rule 45 of the Revised Rules of Court.
They raised errors regarding the alleged fraud, failure to bar the case by prescription or laches, and the improper division of properties.

Whether the registration of the properties in Donata’s name, based on the CFI Order dated October 2, 1952, can be considered fraudulent or procured by mistake as alleged by the heirs of Maximino.
Whether an implied trust was established under Article 1451 or, alternatively, under Article 1456 of the New Civil Code, due to Donata’s actions in having the properties transferred exclusively to her name.
Whether the proceedings in the Special Proceedings No. 928-R, including the issuance and recording of the CFI Order and the subsequent registration of TCTs, were procedurally regular and should enjoy the presumption of validity notwithstanding allegations of non-notice and exclusion of other heirs.
Whether the claims by the heirs of Maximino are barred by prescription or laches given the considerable lapse of time in asserting their rights, considering the familial relationships and the doctrine of co-ownership.
Whether the decision of the RTC (and its affirmation by the Court of Appeals) that granted the partition, annulment, and recovery of possession should be overturned, thereby vindicating the position that the properties rightfully belong solely to the heirs of Donata.