Case Digest (G.R. No. 194897)
Facts:
Substituted Heirs of Jaime S.T. Valiente, represented by Attorney-in-Fact Cyril A. Valiente v. Virginia A. Valiente et al., G.R. No. 194897, November 13, 2023, Second Division, Lopez, M., J., writing for the Court. Petitioners are the substituted heirs of Jaime S.T. Valiente (represented by Cyril A. Valiente); respondents are Virginia A. Valiente (widow of Vicente) and Vicente’s children Rizaardo, Potenciana, Berenice, Visferdo, and Corazon. The dispute concerns several family parcels that allegedly formed part of the estates of spouses Cerilo (d. 1962) and Soledad Sto. Tomas Valiente (d. 1984), notably the Sto. Domingo (Camaligan) and Concepcion Pequena (Naga City) properties. The petition challenges the Court of Appeals’ decision in CA-G.R. CV No. 89127 (Nov. 26, 2009) and its denial of reconsideration (Nov. 12, 2010), which affirmed and modified the Regional Trial Court’s (RTC, Branch 23, Naga City) February 27, 2007 decision in Civil Case No. ’96-3554 ordering judicial partition and awarding damages.After Cerilo’s death, the Valiente siblings undertook extrajudicial settlements and partitions in the 1960s. An extrajudicial settlement dated November 15, 1966, allegedly adjudicated the Sto. Domingo lot to Jaime and Napoleon. In 1977, a notarized deed of sale shows Antero Sto. Tomas (a relative) sold four lots (OCT No. 100) in Concepcion Pequena to Soledad (May 5, 1977) and, days later, Soledad purportedly sold them to Jaime and Napoleon (May 21, 1977). Respondents (children of Vicente) claimed they were fraudulently excluded from inheritance and filed a Complaint for partition and damages on May 23, 1996.
At trial the parties produced competing evidence: respondents relied on testimony alleging Soledad was blind in 1977 and that signatures were forged; petitioners relied on the extrajudicial settlement, tax declarations, registered titles, and the notarized deed of sale. During trial Jaime died (June 23, 2001); his heirs were substituted as petitioners and Cyril was appointed their attorney-in-fact; Napoleon died in 2006. The RTC (Feb. 27, 2007) found that the Marupit and Barlin properties had been acquired by prescription in favor of Jaime and/or Napoleon and that portions of the Concepcion Pequena and Sto. Domingo lots had been sold by Jaime/Napoleon to third parties; it ordered partition among surviving heirs and awarded reimbursement for the portions sold, exemplary damages, attorney’s fees and incidental expenses.
On appeal the Court of Appeals (Nov. 26, 2009) affirmed partition but concluded the original estate should have been divided into three shares (Vicente, Jaime, Napoleon) and adjusted the mathematical allocations and monetary reimbursements accordingly; it also affirmed awards of exemplary damages and fees. The CA denied reconsideration (Nov. 12, 2010). The substituted heirs then filed this Rule 45 Pet...(Pro-only)
Issues:
- Are the RTC and the Court of Appeals correct in declaring that the Concepcion Pequena and Sto. Domingo properties are co-owned by the heirs of Cerilo and Soledad and in ordering judicial partition between petitioners and...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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