G.R. No. 108921 - Villanueva-Mijares vs. Court of Appeals

Petitioners: Josefina Villanueva-Mijares, Waldetrudes Villanueva-Nolasco, Godofredo Villanueva, Eduardo Villanueva, Germelina Villanueva-Fulgencio, Milagros Villanueva-Arquisola, and Concepcion Macahilas vda. de Villanueva. They are the legitimate children of the late Leon Villanueva or, in the case of Concepcion, his widow.
Respondents: Procerfina Villanueva, Prosperidad Villanueva, Ramon Villanueva, Rosa Villanueva, and other members of the Villanueva family who are descendants of Felipe Villanueva, making them blood relatives of the petitioners.

The property originally belonged to Felipe Villanueva, the predecessor-in-interest. It consisted of:

A parcel of land at Estancia, Kalibo, Capiz, with specific boundaries described by adjoining roads and properties.
The land was originally declared under Tax Declaration No. 3888, with an area of 15,336 square meters and a low assessed value.

Upon Felipe’s death, the property was inherited by his eight legitimate children.

In 1952, Pedro obtained his share equivalent to one-sixth (1/6) of the property (1,905 square meters) with a separate declaration (Tax Declaration No. 8085).
The remaining undivided portion of the property, constituting 11,959 square meters, was held in trust by Leon for his co-heirs and declared under Tax Declaration No. 8086.

During Leon Villanueva’s lifetime, his co-heirs repeatedly demanded a division of the property, which did not materialize.
Key transactions include:

Discovery of a purchase by Leon of the shares of four co-heirs (Simplicio, Nicolasa, Fausta, and Maria Baltazar, spouse of Benito) evidenced by a Deed of Sale executed on August 25, 1946, registered only in 1971.
Execution of a sale and partition in July 1970 by Leon in favor of his own children (the petitioners).
Issuance of an Original Certificate of Title (OCT No. C-256) in favor of Leon, with subsequent separate and independent titles obtained by petitioners on April 25, 1975.

Private respondents (also the plaintiffs-appellants in a previous case) filed a suit for partition with annulment of documents, reconveyance, and damages in Civil Case No. 2389 before the Regional Trial Court of Kalibo, Aklan.
The trial court declared the petitioners (defendants in that case) as the legal owners of the property based on the individual titles issued and dismissed the respondents’ action by invoking res judicata.

Private respondents elevated the case to the Court of Appeals (CA-G.R. CV No. 27427) seeking reversal of the lower court decision.
The contentious issue centered on the Deed of Sale of August 25, 1946:

While some co-heirs (Simplicio, Nicolasa, and Fausta) had a valid sale to Leon, the authority of Maria Baltazar to sell her portion (her late husband Benito’s share) was disputed.
The Court of Appeals ruled that, under the Old Civil Code and prevailing jurisprudence, Maria Baltazar had no authority to sell the share pertaining to her minor children since she was not their duly appointed guardian.

Private respondents argued that the sale was fraudulently obtained and that the petitioners’ titles were based on acts tainted by betrayal of an implied trust between Felipe’s children and Leon.
The appellate court considered the issues of laches, estoppel, prescription, and res judicata:

Noting that the applicable prescriptive period had not lapsed (the Deed of Sale was registered in 1971 and the action was filed in 1975).
Emphasizing that the minors involved could not be faulted for any delay in asserting their rights due to their age and the trust placed in Leon as co-heir and administrator.

Whether the appellate court erred in not barring the private respondents’ action based on laches, estoppel in pais, prescription, and res judicata:

Petitioners argued that respondents’ claim was filed too late—more than 29 years after the signing of the disputed Deed of Sale.
Whether the delay in asserting the right, particularly when the involved parties were minors and later became aware of the betrayal, should bar the relief sought by the respondents.

Whether the appellate court erred in declaring the Deed of Sale of August 25, 1946 unenforceable against the private respondents:

The key contention involved the lack of authority of Maria Baltazar to sell her late husband Benito’s share, which belonged to her minor children.
Whether the alleged unauthorized contract, by virtue of the old Civil Code and the requirements for court approval in disposing of minor children’s property, should be deemed permanently unenforceable absent ratification.