Title
Supreme Court
Substituted Heirs of Jaime S.T. Valiente vs. Virginia A. Valiente, et al.
Case
G.R. No. 194897
Decision Date
Nov 13, 2023
The heirs of Jaime Valiente contested the partition of several properties, claiming previous ownership and asserting fraud. The Supreme Court ruled against the heirs, upholding the decisions of lower courts regarding partition.

Case Digest (G.R. No. 194897)
Expanded Legal Reasoning Model

Facts:

  • Parties and Background
    • The petitioners are the substituted heirs of Jaime S.T. Valiente, represented by Attorney-in-Fact Cyril A. Valiente.
    • Respondents are Virginia A. Valiente, Rizaardo A. Valiente, Potenciana A. Valiente, Berenice A. Valiente, Visferdo A. Valiente, and Corazon A. Valiente, heirs of Vicente Valiente.
  • Family and Properties
    • Spouses Cerilo and Soledad Sto. Tomas Valiente had five children: Antonio (deceased during Japanese occupation), Vicente, Elizabeth, Napoleon, and Jaime.
    • Cerilo died in 1962, Soledad in 1984, leaving several properties:
      • Sto. Domingo property: 1,420 sq.m. residential lot in Camaligan inherited from Cerilo.
      • Concepcion Pequeña property: Four parcels totaling 2,272 sq.m., allegedly inherited by Soledad but registered under Antero Sto. Tomas (Soledad’s relative).
      • Marupit property: 810 sq.m. residential lot in Camaligan, actually adjudicated to Jaime by extra-judicial settlement.
      • Barlin property: 111 sq.m. lot in Naga City.
  • Disputes and Claims
    • Respondents alleged that Jaime and Napoleon fraudulently excluded them from the partition and ownership claims, including a contested claim that Soledad sold the Concepcion Pequeña lots to Jaime and Napoleon in 1977 when she was allegedly blind.
    • Complaint for partition and damages filed by the respondents in 1996 against Jaime and Napoleon.
    • Jaime died in 2001; Napoleon died in 2006; heirs substituted accordingly.
  • Trial Court Findings (RTC Decision, Feb 27, 2007)
    • Marupit property was validly adjudicated to Jaime; possession started in 1963.
    • Possession and payments by Jaime and Napoleon over Barlin property also converted ownership by prescription.
    • Sto. Domingo property’s prescription and laches not established as tax declarations transferred late.
    • Deed of sale for Concepcion Pequeña property in favor of Jaime and Napoleon in 1977 declared void due to Soledad’s alleged blindness.
    • Significant portions of the Concepcion Pequeña and Sto. Domingo properties had been sold by Jaime and Napoleon to third parties.
    • Ordered partition of remaining estate portions and reimbursement plus damages to respondents.
  • Court of Appeals (CA) Decision (Nov 26, 2009)
    • Affirmed RTC’s partition but held that since Napoleon was alive at sales, properties divided into three shares (Vicente, Jaime, Napoleon).
    • Adjusted shares accordingly; awarded damages, attorney’s fees, and incidental expenses.
  • Petitioners’ Arguments
    • Contended Concepcion Pequeña property was not part of Soledad’s estate, but bought by Soledad then sold legitimately.
    • Sto. Domingo property was validly and exclusively adjudicated to Jaime and Napoleon with possession ripening into ownership by prescription.
    • Contest awards of damages and partitions among only two parties when three are involved.
  • Respondents’ Counterarguments
    • Emphasized factual findings of courts below affirming co-ownership and partition.
    • Argued issues are factual and not proper for Rule 45 review.

Issues:

  • Whether the Concepcion Pequeña and Sto. Domingo properties are co-owned by the heirs of Cerilo and Soledad and thus subject to partition.
  • Whether the shares allotted to each heir and the corresponding awards of damages and reimbursements are correct.
  • Whether the deed of sale of the Concepcion Pequeña property by Soledad to Jaime and Napoleon is valid or void for alleged forgery.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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