G.R. No. 160956 - Quimpo, Sr. vs. Vda. de Beltran

Eustaquia Perfecto-Abad owned several parcels of land in Goa, Camarines Sur, which include:

Eustaquia died intestate in 1948, leaving the properties to her heirs: her grandchild Joaquin Quimpo and the Abad siblings (Consuelo, Ireneo, Danilo, Marites, Anita, and Helen).

In 1966, Joaquin Quimpo and the Abad respondents entered into an oral partition of Parcels III and IV.

Half of the properties was allotted to Joaquin, while the other half went to the respondents.
No formal document of partition was executed due to Joaquin’s refusal to execute the deed.

Consuelo and Ireneo actively occupied their portions of the San Jose property (Parcel III) and installed tenants in Parcel IV.
Joaquin managed the undivided properties on behalf of himself and the minor heirs (Danilo, Marites, Anita, and Helen), and prevented the minors from taking possession later.

Respondents initiated a complaint for judicial partition and/or recovery of possession with accounting and damages filed before the RTC of Camarines Sur.
Joaquin denied the material allegations, asserting:

Absolute ownership over Parcels III and IV based on purported deeds of sale executed in 1946.
Continuous, peaceful, and adverse possession since 1946, with Consuelo’s occupation alleged to be merely tolerated.

After Joaquin’s death, he was substituted by his wife, Estela Tena-Quimpo, and their children.
The RTC rendered a decision in 1996:

Declared the respondents as co-owners of all properties inherited from Eustaquia.
Rejected Joaquin’s claim of absolute ownership on the ground that the deeds of sale were void for lack of genuine consideration and for being executed when Eustaquia was 91 years old and senile.
Sustained the oral partition by recognizing the long possession and acquiescence by the respective parties.

The RTC ordered the execution of written partition agreements and awarded nominal attorney’s fees and litigation expenses to the respondents.

The CA found that the alleged deeds of sale were vitiated by lack of true consideration and Eustaquia’s mental incapacity.
It held that continuous occupation and the exercise of ownership by respondents were sufficient to establish an actual partition over Parcels III and IV.
The CA rejected the petitioners’ arguments concerning prescription and laches, noting that co-ownership is not barred by these doctrines so long as no repudiation occurs.
The grant of attorney’s fees to the respondents was likewise sustained.

The CA’s ruling on the invalidity of the deeds of sale, arguing that they should establish absolute ownership over the subject parcels.
The existence of co-ownership between petitioners and respondents.
The sufficiency of evidence establishing the respondents’ filiation to Eustaquia.
The application of prescription and laches to bar the respondents’ claims.
The award of attorney’s fees in favor of the respondents.

The petitioners insisted that the notarized deeds of sale and tax declarations supported their claim, while dismissing the credibility and weight accorded by the lower courts to the respondents’ evidence.

Whether the deeds of sale executed in 1946, which allegedly involved false and fictitious consideration due to Eustaquia’s advanced age and incapacity, could establish Joaquin Quimpo’s claim to absolute ownership over Parcels III and IV.
Whether an actual and enforceable oral partition existed among the heirs, as evidenced by the long, uninterrupted possession and occupation of the properties by the respondents.
Whether the continuous, peaceful, and adverse possession by the respondents, combined with Joaquin’s acquiescence, forms a sufficient basis to establish co-ownership against claims of absolute ownership by petitioners.
Whether the doctrines of prescription and laches apply to bar the respondents’ action in seeking a partition of the common property.
Whether the award of attorney’s fees in favor of the respondents was proper under the circumstances presented in the case.