G.R. No. 199874 - People vs. Fang y Gamboa

Petitioner Aida Robles, accompanied by her husband Rafael Penolio, initiated the action.
Respondents include the Court of Appeals, Aniceto B. Parreno (the vendee), and the Register of Deeds of Negros Occidental.
The dispute centers on two properties originally belonging to the late Eligio A. Robles and his wife Melania Cuaycong, which form part of their conjugal estate.

Eligio A. Robles registered Lot No. 1304, covering 4.2038 hectares, in his name jointly with his wife.
He initiated registration proceedings for Lot No. 1305-A, covering 5.8685 hectares; after his death, the title was issued in the name of his surviving wife and “the heirs of Eligio Robles.”
Petitioner Aida Robles is established as a co-heir, being the granddaughter of Eligio through his deceased son, Jose. She is entitled to a 1/44 share of the disputed properties.

On June 20, 1957, Melania and nine other heirs (excluding petitioner Aida and another co-heir, Eva Robles) executed a general power of attorney in favor of Francisco, authorizing him to alienate and encumber the disputed properties.
In October 1960, Francisco executed a private deed of sale in favor of respondent Aniceto B. Parreno.
A notarized deed of sale was later executed on January 20, 1965 for the price of P4,300.00.
The general power of attorney was registered in the office of the Register of Deeds of Negros Occidental and was treated as a “Declaration of Heirship,” which resulted in the issuance of new titles naming respondent Parreno as the owner of the entire properties, effectively ignoring petitioner’s 1/44 share.

On September 18, 1967, petitioner Aida Robles filed a complaint in the Negros Occidental Court of First Instance seeking cancellation of the titles issued in respondent Parreno’s name.
Her action was premised on her right to legally redeem her co-heir interest under Article 1088 of the Civil Code, asserting that the titles were issued in disregard of her share.
The lower court dismissed her complaint, and the appellate court remanded the case for impleading the sellers (the vendor co-heirs) as indispensable parties.

Respondent court’s decision stressed that the vendors (the co-heirs who executed the power of attorney) were indispensable to the case in order for them to justify the legality of the sale and to avoid potential liability, including criminal responsibility for estafa.
Petitioner contended that her principal action was not fundamentally against the vendors but rather against respondent Parreno and the Register of Deeds for the wrongful registration of the General Power of Attorney and the consequent cancellation of her rightful share.
The petitioner argued that if her action, essentially one for legal redemption, could be decided solely between her and the vendee, the vendors-coheirs were not indispensable parties to her claim.

Whether the vendors-coheirs (the sellers) are indispensable parties to the action for cancellation of titles and legal redemption.

Does the inclusion or exclusion of the vendors-coheirs affect the adjudication of petitioner Aida Robles’ rights as a 1/44 co-heir?
Can legal redemption under Article 1088 be properly enforced without their impleading?

Whether the Register of Deeds committed an administrative fault by registering a general power of attorney as a “Declaration of Heirship” and failing to provide proper notice for redemption.

Was the conversion of the power of attorney into a document effecting the transfer of the entire property legally valid?
Did the Register of Deeds’ practices lead to the irregular issuance of titles?

Whether the proper remedy under the circumstances is cancellation of the wrongful titles and enforcement of the legal redemption rights of a co-heir.