Case Summary (G.R. No. 160556)

Background of the Case

• Teodora Rosario owned a 211.80-square meter parcel of land in San Carlos City, Pangasinan, covered by TCT No. 12951.
• She died intestate on January 19, 1970, leaving her spouse Isidro Bautista and five children: Teofilo, Alegria, Angelica, Pacita, and Gil.
• On April 21, 1981, Isidro and four of the children executed a Deed of Extra-Judicial Partition, waiving Isidro's share in favor of Alegria, Angelica, Pacita, and Gil, excluding Teofilo.

Sale and Subsequent Transactions

• Alegria and Angelica sold their acquired shares of the property to Pacita and her common-law husband, Pedro Tandoc, on May 14, 1981.
• Pacita and Pedro obtained tax declarations and TCT No. 18777 in their names for 209.85 square meters of the property.
• On April 13, 1993, Pacita conveyed half of the property to Cesar Tamondong, Pedro's nephew.

Initiation of Legal Action

• On January 24, 1994, Teofilo, through his attorney-in-fact Francisco Muñoz, filed a complaint against his siblings and others for annulment of documents, partition, recovery of ownership, possession, and damages.
• Teofilo alleged that he was defrauded of his rightful share and claimed that the sale to Tamondong was fictitious due to Pacita's illness.

Defendants' Response

• The defendants, including Alegria and Angelica, claimed they were unaware of the partition's contents and that Pacita misled them into signing the Deed of Extra-Judicial Partition.
• They asserted that they trusted Pacita and were unaware of the fraudulent nature of the documents until Teofilo's complaint was filed.
• Pedro and Tamondong claimed they were buyers in good faith and argued that the complaint was barred by prescription.

Trial Court's Decision

• On June 24, 1999, the Regional Trial Court ruled in favor of Teofilo, declaring the Deed of Extra-Judicial Partition and subsequent documents null and void, ordering partition among the heirs, and requiring Tamondong and Tandoc to vacate the premises.

Appeal and Court of Appeals' Ruling

• Pedro and Tamondong appealed the trial court's decision, and on February 21, 2003, the Court of Appeals reversed the ruling, dismissing Teofilo's complaint on the grounds of prescription.
• The Court of Appeals held that Teofilo had constructive notice of the partition due to its registration and failed to file his objections within the four-year period.

Supreme Court's Analysis

• The Supreme Court found merit in Teofilo's petition, noting that the Deed of Extra-Judicial P...continue reading