G.R. No. 125896 - People vs. Sullano

The dispute arose from the petition filed by Reynaldo Reyes—as heir of Vitaliano Reyes—challenging lower court decisions.
The Regional Trial Court (RTC), Branch 266 of Pasig City, in Civil Case No. 71077-TG rendered a decision on April 12, 2013, dismissing the petitioner's complaint for recovery of ownership, quieting of title, and annulment of the deed of sale.
The Court of Appeals (CA) in its February 16, 2016 Decision affirmed the RTC ruling, a ruling later denied for reconsideration by the CA in its June 9, 2016 Resolution.
Petitioner subsequently elevated the case by filing a petition for review on certiorari under Rule 45.

The subject matter is an unregistered parcel of land situated on Quezon St., Bagumbayan, Taguig, with a total area of 463 square meters as indicated in Tax Declaration No. 9700 (5277).
The property originally belonged to Julian Reyes and his wife Marcela Reyes, who had nine children: Vitaliano, Maria, Felicidad, Ireneo, Isidoro, Anastacio, Julia, Vicente, and Isadora.
Upon the deaths of Julian (September 21, 1944) and Marcela (October 31, 1964), the property devolved into the hands of the heirs of the Reyes estate.

On August 30, 1975, the heirs executed an instrument titled "Partihan At Bilihan Nang Kalahating Bahagi ng Lupang Tirahan Sa Labas ng Hukuman" wherein:

Half of the subject property (231.5 sqm) was sold to one of the heirs, Anastacio.
Another quarter (approximately 116 sqm) was occupied by the children of Vitaliano, which included the petitioner and Fermin Reyes.
The remaining quarter was sold by Isidoro to respondents, Wilfredo and Melita Garcia, as per the Deed of Sale dated August 16, 1989.

Petitioner later discovered Isidoro’s sale to the respondents when an ejectment case was filed against Fermin, prompting the petition for recovery of ownership and for judicial quieting of title.
Petitioner argued that the deed of sale dated August 16, 1989 is void to the extent that it dispossessed the interests of the other heirs, contending that Isidoro lacked authority to alienate the property the estate originally owned.

Motion to dismiss on the grounds of res judicata, failure to state a cause of action, and non-impleading of indispensable parties.
Allegation that the assessed property value (P19,040.00) is below the jurisdictional threshold (P50,000.00).
Contention that the petitioner was not the real party in interest as the property is an undivided co-owned asset.

They also argued that even though no formal partition agreement was executed, the heirs had effectively agreed to divide the property, thereby validating the sale of Isidoro’s share.

Evidence presented by the parties established that the subject property remains co-owned by the heirs of Julian and Marcela.
The RTC determined that jurisdiction is based on the petitioner's allegations and the principal relief sought, rendering the property’s assessed value irrelevant to jurisdiction.
Both the RTC and CA concluded that while Isidoro validly sold his pro indiviso share to the respondents, the proper legal remedy for disputes among co-owners is partition—not annulment of sale or recovery of possession.

Whether the appellate court erred in ruling that the proper remedy for the dispute is an action for partition of the subject property.

Petitioner contended that partitioning the 231.5 sqm property would render it unserviceable, with each of the nine heirs receiving an impractically small portion.

Whether the appellate court erred in not declaring the Deed of Sale dated August 16, 1989 null and void concerning the interests of the other co-heirs.

The petitioner argued that since Isidoro was entitled to only his share (approximately 25.66 sqm), the sale effectively encroached upon the remaining interests of the other heirs and should therefore be nullified.