G.R. No. L-58674-77 - People vs. Panis

Jose Santos, a rice farmer, previously married to Josefa Santos with several children from that marriage, later courted Maria D. Santos after the death of his second wife.
Maria D. Santos, originally married to Dominador Mendoza (with whom she had seven children) and widowed in 1990, became involved with Jose, who was significantly older at the time of their marriage.
Jose had eight alleged children with his first wife, Josefa, although some of these children had predeceased him; their rights were asserted either by themselves (if living) or by representation through their children.
Disputes arose regarding the legitimacy and representation of the children, particularly concerning the alleged eighth child, Ruben, and the inclusion of his descendants.

Jose was involved in an agricultural tenancy dispute with the Gaspar family, his landlord, which culminated in a decision awarding him peaceful possession of the land he cultivated.
On May 28, 2002, the Gaspar family executed three instruments titled “Deed of Donation” transferring a total of 6,000 square meters of rice land (allegedly in “Disturbance Compensation of Tenant”) to Jose.
Jose disposed of portions of this land through sales and donations to various individuals, with specific lot sizes and dates recorded; among these was the transfer resulting in a Kasulatan ng Pagkakaloob Pala executed on December 4, 2007, by which Jose gratuitously transferred 805 square meters to Maria.
Despite the recorded 805 sqm donation, subsequent subdivision left the subject property at 694 sqm, currently documented under Transfer Certificate of Title (TCT) No. T-289268 and registered in the name “Jose L. Santos, Filipino, of legal age, widower, now married to Maria Santos.”

At the time of his death on June 1, 2010, Jose left behind Maria and five surviving children from his first marriage; the children of those who predeceased him (Nestor, Milagros, and Ruben) were to inherit by right of representation.
Following Jose’s death, a dispute arose over the partition of the subject property. Maria insisted that she was the sole owner on the basis of the Kasulatan ng Pagkakaloob Pala, while Jose’s surviving children and grandchildren sought a division into equal portions.
Edgardo’s group of petitioners (comprising several of Jose’s children and the represented children of the predeceased heirs) filed a complaint for partition, accounting, and damages against Maria.
During the proceedings, issues emerged regarding the proper inclusion of the children of Ruben (Bettina and Reuben Joseph) and the validity of the donation instrument executed by Jose in favor of Maria.

The Regional Trial Court (RTC) rendered an Order on December 1, 2017, declaring that Maria and Jose’s children (including representatives of predeceased heirs) were co-owners of the 694 sqm property, and ordered a partition in eight equal parts with appropriate representation.
Subsequent motions for reconsideration by the parties led the RTC, on March 26, 2018, to grant the petitioners’ partial motion while denying Maria’s motion, confirming its jurisdiction over the partition case.
The Court of Appeals (CA) subsequently modified the RTC’s decision on May 3, 2019 by declaring Maria the sole owner of one-half of the property (as her share in the absolute community property) and ordering that the other half be partitioned equally among the seven children of Jose who were able to prove their filiation, excluding the children of Ruben.
In further proceedings, motions for partial reconsideration were denied by the CA in a Resolution dated November 26, 2019.
On petition for review on certiorari, issues regarding the mode of appeal and evidentiary matters came under scrutiny, leading to consolidation of related cases and a re-examination of the factual and legal bases underlying the previous rulings.

Whether Maria properly availed the remedy by filing an ordinary appeal under Rule 44 versus a petition for review on certiorari under Rule 45.
Whether the dispute involving the administration of Jose’s estate, particularly in an action for partition, falls within the purview of a Regional Trial Court acting as a general jurisdiction court.

Whether the Kasulatan ng Pagkakaloob Pala executed by Jose transferring 805 sqm (later diminished to 694 sqm) to Maria during their marriage is valid.
Whether such donation between spouses during the marriage violates Article 87 of the Family Code and is hence deemed null and void.

Whether Jose acquired the subject property from the Gaspar family by gratuitous title or whether the transfer was in fact an onerous transaction made as disturbance compensation for the cessation of his tenancy.
Whether the inserted phrase “Disturbance Compensation of Tenant” (allegedly added by a different font and without countersignature) affects the true nature of the transfer and is admissible as evidence.

Whether the subject property forms part of the absolute community of property of Jose and Maria, given its acquisition during their marriage.
Whether the property should be distributed as Jose’s separate asset or as part of the conjugal (community) property requiring proper collation and partition.

Whether the children of Ruben (Bettina and Reuben Joseph), despite the absence of a presented birth certificate in the lower proceedings, are entitled to inherit as legitimate descendants.
Whether Maria’s failure to contest the filiation of Ruben via a Request for Admission constitutes an implied admission warranting the inclusion of his children in the partition.