G.R. No. 139524 - Santos vs. Santos

Ladislao C. Santos (Appellant) filed a complaint for judicial partition against his brother Eliseo M. Santos and Eliseo’s son Philip Santos (Appellees) involving the property of their deceased sister, Isidra M. Santos.
Isidra Santos died intestate and without issue on April 1, 1967, owning a parcel of land in San Mateo, Rizal (referred to as the "Isidra property"), approximately 391 square meters, covered initially by Tax Declaration No. 655, later changed to No. 1115.
Their father, Bonifacio Santos, died earlier owning Lot 1522 and other lands in the same locality. Ladislao and Eliseo are heirs of this estate.

May 29, 1967: Ladislao and wife executed a Deed of Absolute Conveyance with right of way for 3,000 square meters of Lot 1522 to Eliseo.
1969: Alleged Combined Deed of Partition purportedly executed between Ladislao, Eliseo, and their spouses, whereby the entire Isidra property was deeded to Eliseo Santos.
Eliseo allegedly conveyed the Isidra property to his son Virgilio Santos, who later sold it to Philip Santos in 1980. Tax Declarations for the property changed accordingly to Virgilio and then to Philip.
The above conveyances and tax declaration changes were challenged by Ladislao Santos on grounds of illegality and lack of proof of ownership transfer.

The Regional Trial Court dismissed Ladislao’s complaint citing lack of proof and the possible bar of acquisitive prescription.
The Court of Appeals reversed the trial court decision, ruling that Ladislao and Eliseo were each entitled to undivided one-half shares of the Isidra property.
Evidence included:

Testimonies from Virginia Santos (widow of Virgilio), Philip Santos, and the municipal assessor concerning the alleged Combined Deed of Partition and tax declaration changes.
Copies of tax declarations showing ownership registration in Virgilio’s and Philip’s names.
Lack of original deeds or authenticated copies of the Combined Deed of Partition.

Key testimony from the municipal assessor indicated no actual knowledge of the deed used to transfer ownership for tax purposes since records were destroyed in a fire in 1977.
The Appellees failed to sufficiently prove the loss or destruction of all original copies of the alleged deed required to admit secondary evidence under the Rules of Evidence.

Ladislao Santos filed a petition for review with the Supreme Court assailing the Court of Appeals decision, raising issues on:

Legality and regularity of the transfer of the Isidra property to Virgilio and Philip Santos.
The sufficiency of proof regarding alleged fraud or misrepresentation in cancelling the tax declaration in Isidra’s name.
Whether the action for partition was barred by acquisitive prescription or laches.
The rights of Philip Santos as buyer in good faith.

Whether the transfers of the Isidra property from Eliseo Santos to Virgilio Santos, and subsequently to Philip Santos, were valid and lawful.

Whether the action for partition filed by Ladislao Santos is barred by ordinary acquisitive prescription of ten years or laches.

Whether the Court of Appeals erred when it awarded each of the brothers an undivided one-half share (50%) in the Isidra property despite the alleged conveyances.

Whether petitioners conclusively proved their exclusive ownership by proper submission of evidence, including original or properly authenticated deeds.

Whether the tax declarations issued in the name of Virgilio and Philip Santos constitute conclusive evidence of ownership of the Isidra property.