Case Summary (G.R. No. 184454)
Petitioners' Claims
The Petitioners assert that Lun and Fieng arrived in the Philippines from China in 1929 and acquired the properties using inherited capital from their father, Co Chaco. The Gubat property, mentioned to contain 720.68 square meters, was reportedly placed under Fieng's name according to a customary practice in China. The Barcelona property was acquired by Co Chaco in 1923. The Petitioners argue that Lun made significant financial contributions towards the properties, including paying realty taxes and conducting repairs. They state that while there were intentions to partition the properties in 1946, this was halted by their mother to maintain family unity. They claim Lun supported Fieng financially during various business ventures without repayment, further establishing a claim of co-ownership.
Respondents' Counterclaim
Conversely, the Respondents assert that the Gubat property was solely owned by Fieng, who allegedly purchased it from Rocha in 1935. They provide documentation indicating Fieng constructed a commercial building and conducted business on the property. The Respondents maintain that Lun was never actively involved in the acquisition of either property and that Fieng’s ownership was well-documented through tax declarations and sales contracts. They argue that Lun had only managed the properties as an administrator, particularly after Fieng's death in 1958.
Regional Trial Court's Ruling
The Regional Trial Court (RTC) initially sided with the Petitioners, recognizing their claims and establishing co-ownership based on the documentary evidence submitted. In its ruling, the RTC acknowledged that although the properties were in Fieng's name, the evidence pointed to a joint ownership based on contributions and historical context.
Court of Appeals' Ruling
Upon appeal, the Court of Appeals (CA) reversed the RTC's decision, asserting exclusive ownership of the properties by Fieng and his heirs. The CA determined that the Petitioners failed to substantiate their claims of co-ownership with sufficient evidence, highlighting the lack of credible documentation supporting the alleged business partnership between Lun and Fieng, and emphasized that Lun’s actions did not reflect ownership but rather a role as an administrator.
Issue Before the Supreme Court
The primary issue was whether the CA erred in its conclusion that there was no co-ownership and in declaring Fieng as the exclusive owner of the properties.
Supreme Court's Ruling
The Su
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Case Background
- The case involves two properties in Sorsogon province: the Gubat property (commercial/residential land at Poblacion, Gubat, covering 720.68 sq meters) and the Barcelona property (cocoa and residential land in Luneta barrio, Barcelona).
- Petitioner Co Giok Lun and respondent Jose Co are descendants of two brothers: Co Giok Lun (deceased) and Co Bon Fieng (deceased), the latter being the father of respondent Jose Co.
- The properties were allegedly co-owned by these two brothers.
- The dispute arose from petitioners filing a complaint for partition and damages before the Regional Trial Court (RTC) of Gubat, Sorsogon.
Ownership Claims and Historical Background
- Petitioners assert that Lun and Fieng came from China in 1929, that the capital for the Gubat property came from an ancestral P8,000 capital from their father, Co Chaco, and that properties were customarily placed in the eldest son's name (Fieng) in Chinese tradition.
- Petitioners claim that the Gubat property was purchased using business income from a partnership business called Philippine Honest and Company.
- Lun allegedly lived in and maintained the Gubat property, paying taxes and bearing financial burdens, including loans and obligations incurred by Fieng.
- Respondents claim that Fieng exclusively acquired the Gubat property by purchase from Crispina Rocha in 1935 and adjoining parcels in 1936, supported by proper notarized deeds.
- Respondents deny the partnership/business relationship between Lun and Fieng, asserting Lun was only an administrator and later tolerated occupant.
- Respondents maintain that Chaco gave the Barcelona property exclusively to Fieng as an advance inheritance.
Petitioners' Evidentiary Presentation
- Petitioners presented tax declarations in Fieng's name but paid by Lun (1929-1983).
- Insurance documents listing Lun as administrator of the property.
- Deed of Sale dated 24 August 1923 for the Barcelona property purchased by Chaco.
- Testimonies regarding the Chinese custom of naming eldest son as owner.
- Records of financial transactions showing Lun's payments of loans and