Case Digest (G.R. No. 151334)
Facts:
This case involves a property dispute among the heirs of Leandro Figuracion, who died intestate in May 1958. The petitioners are Carolina (Carlina) Vda. De Figuracion, the surviving spouse of Leandro, and the heirs of his children Elena Figuracion-Ancheta, Hilaria A. Figuracion (Felipa Figuration-Manuel, Mary Figuracion-Ginez, and Emilia Figuracion-Gerilla as respondents). The contested properties are two parcels of land (Lot Nos. 2299 and 705) in Urdaneta, Pangasinan, acquired by Leandro during his lifetime, covered by Transfer Certificates of Title (TCT) Nos. 4221-P and 4220-P. Additionally, the controversy includes Lot No. 707 owned by Eulalio Adviento, covered by Original Certificate of Title (OCT) No. 15867, which was inherited by his legitimate heirs Agripina Adviento and Carolina, Eulalio's daughter from his second marriage.
On November 28, 1961, Agripina executed a Deed of Quitclaim over the eastern half of Lot No. 707 in favor of her niece, Emilia. Meanwhile, on De
Case Digest (G.R. No. 151334)
Facts:
- Parties and Background
- The petitioners are the heirs of Leandro Figuracion (Leandro), who died intestate in May 1958, with Carolina (Carlina), his surviving spouse, as one petitioner. Other petitioners are his children: Elena Figuracion-Ancheta, Hilaria A. Figuracion (Hilaria), Felipa Figuracion-Manuel (Felipa), Quintin Figuracion, and Mary Figuracion-Ginez. The respondent is Emilia Figuracion-Gerilla, also a child of Leandro and Carolina.
- Two parcels of land in Urdaneta, Pangasinan, titled under Leandro, are subject to dispute:
- Lot No. 2299 (7,547 sq.m.), originally under TCT No. 4221-P (later replaced by TCT No. 101331 due to sale of portion).
- Lot No. 705 (2,900 sq.m.), under TCT No. 4220-P.
- Leandro executed a Deed of Quitclaim in 1955 over these properties to his six children, reserving the fruits and use for him and his spouse Carolina.
- Lot No. 707 Ownership and Transactions
- Lot No. 707 (3,164 sq.m.) originally owned by Eulalio Adviento (Eulalio), covered by OCT No. 15867 issued in 1917.
- Eulalio had two wives: first wife Marcela Estioko (mother of Agripina Adviento) and second wife Faustina Escabesa (mother of Carolina, petitioner).
- On November 28, 1961, Agripina executed a Deed of Quitclaim over the eastern half of Lot No. 707 in favor of her niece Emilia (respondent).
- On December 11, 1962, Carolina executed an Affidavit of Self-Adjudication claiming the whole Lot No. 707 as sole heir of Eulalio and Faustina, then sold Lot No. 707 via Deed of Absolute Sale to petitioners Hilaria and Felipa. The OCT was cancelled and TCT No. 42244 was issued in their names.
- Subsequent Events
- Emilia left for the United States in 1971, returned in 1981, and built a house on the eastern half of Lot No. 707, relying on the Deed of Quitclaim from Agripina.
- In 1994, conflict arose when Hilaria and agents threatened to demolish Emilia’s house, prompting Emilia to seek legal partition of Lot No. 707, Lot No. 2299, and Lot No. 705.
- Parties failed to reach an amicable settlement at the Katarungang Pambarangay.
- Trial Proceedings and Findings
- Emilia filed a complaint in 1994 for partition, annulment of documents (Affidavit of Self-Adjudication, Deed of Absolute Sale, TCT No. 42244), reconveyance of eastern half of Lot No. 707, quieting of title, and damages.
- Petitioners raised defenses including prescription and laches, indefeasibility of Torrens title, and repudiation of co-ownership due to adverse possession.
- RTC in 1997:
- Dismissed Emilia’s complaint for partition, reconveyance, quieting of title, and damages.
- Declared null and void the Affidavit of Self-Adjudication, Deed of Absolute Sale, and the TCT affecting Lot No. 707.
- Held partition of Lots 2299 and 705 premature as ownership had not been transmitted to heirs.
- Refused to adjudicate Lot No. 707’s eastern half ownership to Emilia, pending estate settlement of Eulalio.
- Court of Appeals (CA) Decision in 2001
- Reversed RTC on Lot No. 707, ruling that partition was proper as Carolina only sold her share (A3/8), and the Deed of Absolute Sale did not cover Agripina’s share.
- Directed the partition of Lot No. 707 among Emilia (A1/2 eastern portion), Felipa and Hilaria (A1/4 each).
- Affirmed RTC’s dismissal of partition on Lots 2299 and 705 as premature.
- Supreme Court (SC) Prior Decision in 2006 (G.R. No. 154322)
- Denied Emilia’s appeal.
- Agreed that Lot Nos. 2299 and 705 partition was premature and ownership issues remained unresolved.
- Current Petition for Review on Certiorari (G.R. No. 151334)
- Petitioners contest the CA’s 2001 decision, seeking reversal.
- They argue that the Deed of Quitclaim in favor of Emilia was essentially a donation with no acceptance and thus void.
- They point to alleged defects: unregistered deed, lack of copies in relevant offices, improper notarization.
- Emilia argues the Deed of Quitclaim is an onerous donation requiring no acceptance; thus valid.
Issues:
- Procedural and Evidentiary Issues
- Whether petitioners can raise for the first time on appeal that the Deed of Quitclaim was a defective, unaccepted donation.
- Substantive Ownership Issues on Lot No. 707
- Whether respondent Emilia owns the eastern half of Lot No. 707 by virtue of the Deed of Quitclaim from Agripina.
- Whether petitioners’ acquisition by Deed of Absolute Sale and registration extinguished Emilia’s claim or rights.
- Whether petitioners or their predecessors repudiated the co-ownership, thus initiating the period for acquisitive prescription or estoppel by laches.
- Whether partition of Lot No. 707 can be compelled by Emilia given the co-ownership status and legal titles.
- Proper apportionment of Lot No. 707 shares among the parties considering applicable succession and marital property law under the Old Civil Code.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)