G.R. No. 181508 - Constantino vs. Heirs of Constantino Jr.

Case Summary (G.R. No. 181508)

Petitioners

Petitioners claimed valid execution of a document denominated “Pagmamana sa Labas ng Hukuman” dated 10 August 1992 dividing the 240 sq. m. parcel between Oscar and Maxima (later Casimira), resulting in issuance of tax declarations in their names. They asserted the 1992 instrument reflected a voluntary and mutual agreement among the descendants, and relied on an earlier Deed of Extrajudicial Settlement with Waiver dated 5 December 1968 (covering a 192 sq. m. lot) as evidence that respondents’ representatives had acquiesced to the arrangement.

Respondents

Respondents, heirs of Pedro Jr., filed suit for nullification of the Pagmamana, annulment of subsequent tax declarations issued in petitioners’ names, and reinstatement of Tax Declaration No. 20814 in the name of Pedro Sr. They alleged the 1992 Pagmamana and the tax declarations issued thereon resulted from a simulated, fabricated and fictitious instrument that misrepresented petitioners as the sole heirs and effectively cancelled the ancestral tax declaration.

Key Dates and Procedural Posture

Relevant dates: Extrajudicial Settlement with Waiver — 5 December 1968; Pagmamana sa Labas ng Hukuman — 10 August 1992; Complaint filed — 17 June 1999; RTC Decision — 27 October 2003 (dismissing complaint and upholding Pagmamana and related tax declarations); Court of Appeals Decision — 31 May 2007 (reversing RTC and ruling for respondents); Supreme Court Decision — October 2, 2013 (reversing CA). The petition reached the Supreme Court by a Petition for Review on Certiorari under Rule 45, Rules of Court.

Applicable Law and Procedural Rules

Governing constitutional framework: 1987 Philippine Constitution (applicable because decision date is after 1990). Primary substantive and remedial provisions relied upon: Civil Code (Article 1409 on contracts contrary to law, and Articles 1411–1412 on effects of illegality and the in pari delicto doctrine); Rules of Court provisions governing pre-trial admissions and their binding effect (Section 7, Rule 18) and admissions during proceedings (Section 4, Rule 129). The Court also relied on established jurisprudential formulations of the in pari delicto doctrine and on authorities concerning privity in estate and judicial admissions (cases cited in the record).

Core Facts Relevant to Disposition

Pedro Constantino, Sr. left multiple parcels including the 240 sq. m. lot (Tax Declaration No. 20814) and a 192 sq. m. lot (Tax Declaration No. 9534). Upon his death he was survived by six children, whose descendants later executed instruments purporting to partition or appropriate parts of the estate. The 1968 Extrajudicial Settlement with Waiver purported to adjudicate the 192 sq. m. parcel, while the 1992 Pagmamana purported to allocate the 240 sq. m. parcel between certain descendants to the exclusion of others. Parties entered stipulations at pre-trial, including admissions by respondents that the 192 sq. m. lot covered by Tax Declaration No. 9534 was transferred from Pedro Sr. to Maria Constantino (respondents’ predecessor).

Issue Presented

Whether the Court of Appeals erred in refusing to declare the Pagmamana and the Extrajudicial Settlement void on the ground that the doctrine of in pari delicto barred relief, and whether the CA correctly disregarded the parties’ stipulations and admissions made at pre-trial and the effect of privity and judicial admissions on respondents’ claims.

Trial Court Ruling

The Regional Trial Court applied the doctrine of in pari delicto, concluding that both sets of heirs had acted equally at fault by executing instruments that excluded other heirs. Relying on precedents and equitable maxims, the RTC found the parties in pari delicto and dismissed the complaint for nullification, thereby upholding the Pagmamana and the derived tax declarations.

Court of Appeals Ruling

The Court of Appeals reversed the RTC. It concluded that the 192 sq. m. lot adjudicated in the 1968 deed belonged to Pedro Jr. (despite a typographical error in the deed), not to Pedro Sr., and therefore the Extrajudicial Settlement pertained to a distinct property and was valid. On that basis the CA found it erroneous for the RTC to declare the parties in pari delicto and ruled in favor of the respondents (heirs of Pedro Jr.).

Supreme Court’s Legal Analysis — Doctrine of in pari delicto and its Limits

The Supreme Court explained the meaning and scope of in pari delicto (both parties equally at fault) as embodied in Articles 1411–1412 and related maxims (ex dolo malo non oritur actio; in pari delicto potior est conditio defendentis). The Court clarified that Article 1412 addresses contracts void for illegality of cause or object that do not amount to criminal offenses and governs parties’ rights and obligations in such contracts. Crucially, the Court held that the pari delicto doctrine does not automatically apply where multiple separate deeds purport to assign parts of a single decedent’s estate so as to exclude co-heirs; applying the doctrine in that context would have the anomalous effect of validating both contradictory deeds rather than nullifying the illegitimate circumvention of heirs’ legitimes. Accordingly, the in pari delicto rule was inapplicable as a basis to leave the parties “where they are.”

Supreme Court’s Legal Analysis — Void Agreements and Article 1409

The Court emphasized that agreements whose object or purpose circumvent mandatory succession rules and legitimes are inexistent and void under Article 1409 of the Civil Code. Where a settlement or partition excludes heirs and thereby deprives them of their legitimes, the instrument is void ab initio and cannot be validated by time or ratification. The Court concluded that the underlying agreements resulting in the two deeds were void because they assigned portions of the same ancestor’s estate by excluding other heirs and circumventing statutory succession protections.

Supreme Court’s Legal Analysis — Privity, Judicial Admissions, and Evidentiary Consequences

The Court reaffirmed that respondents were privies in estate to their predecessor (Maria Laquindanum) and therefore bound by conditions and agreements that attached to the property — they “stand in the shoes” of their predecessor. The Court further emphasized the binding charac

Case Syllabus (G.R. No. 181508)

Case Citation and Procedural Posture

Reported at 718 Phil. 575, Second Division, G.R. No. 181508, decided October 02, 2013; Decision penned by Justice Perez.
Petition for Review on Certiorari under Rule 45 of the Rules of Court assails the Court of Appeals (CA) 31 May 2007 Decision in CA-G.R. CV No. 81329.
The CA had reversed the Regional Trial Court (RTC), Branch 18, Malolos City, Bulacan, Decision dated 27 October 2003 in Civil Case No. 630-M-99 (Complaint for Declaration of Nullity of "Pagmamana sa Labas ng Hukuman," Tax Declaration Nos. 96-10022-02653 & 96-10022-02655, with prayer for preliminary injunction and damages).
Supreme Court disposition: CA Decision reversed; the Pagmamana sa Labas ng Hukuman and the Extrajudicial Settlement with Waiver declared void; ordered partition of Pedro Constantino Sr.'s estate with full participation of all heirs.

Parties and Family Relationships (Pertinent Heirs and Lines of Descent)

Decedent: Pedro Constantino, Sr., owner of several parcels of land, including an unregistered parcel declared for taxation under Tax Declaration No. 20814 (240 sq. m) situated at Sta. Monica, Hagonoy, Bulacan.
Surviving children of Pedro Sr.:
- Pedro Constantino, Jr. — grandfather of respondents; had four (4) children by Felipa dela Cruz (including Maria Constantino, mother of respondent Asuncion Laquindanum).
- Antonia Constantino — later died without issue.
- Clara Constantino — later died without issue.
- Bruno Constantino — survived by six (6) children including petitioner Casimira Constantino-Maturingan.
- Eduardo Constantino — survived by his daughter Maura.
- Santiago Constantino — survived by five (5) children including petitioner Oscar Constantino.
Petitioners: Oscar Constantino, Maxima Constantino, and Casimira Maturingan (grandchildren of Pedro Sr.).
Respondents/plaintiffs below: Asuncion Laquindanum and Josefina Cailipan, great-grandchildren of Pedro Sr., representing heirs of Pedro Jr.

Documents, Tax Declarations, and Conveyances at Issue

Original tax declaration: Tax Declaration No. 20814 (240 sq. m) in name of Pedro Sr.
Deed dated 5 December 1968: Deed of Extrajudicial Settlement with Waiver (Doc. No. 319, Book No. 11, Series of 1968), executed by heirs of Pedro Jr. (Angelo, Maria, Arcadio, Mercedes) adjudicating a 192 sq. m lot (Tax Declaration No. 9534/9535 sequence referenced).
Deed dated 10 August 1992: Document denominated "Pagmamana sa Labas ng Hukuman" executed by certain heirs (petitioners claim it was a valid product of mutual and voluntary agreement).
Alleged subsequent tax declarations and transfers:
- Tax Declaration No. 02010-2170-33235 purportedly issued in the name of petitioners Oscar and Maxima, effecting cancellation of TD No. 20814.
- Petitioners allegedly divided the 240 sq. m parcel into two halves (120 sq. m each), resulting in issuance of Tax Declaration No. 96-10022-02653 in the name of Oscar (120 sq. m) and Tax Declaration No. 96-10022-02652 in the name of Maxima; Maxima's share later conveyed to Casimira resulting in Tax Declaration No. 96-10022-02655.

Factual Allegations and Parties’ Contentions

Respondents’ complaint (filed 17 June 1999): Alleged petitioners asserted ownership over entire 240 sq. m parcel in October 1998, displacing respondents who occupied a portion; alleged issuance of new tax declaration was unlawful and derived from a simulated, fabricated, and fictitious "Pagmamana sa Labas ng Hukuman" dated 10 August 1992 in which petitioners misrepresented themselves as sole heirs of Pedro Sr.; sought nullification of the Pagmamana, annulment/reinstatement of tax declarations (including reinstatement of TD No. 20814 in name of Pedro Sr.), and damages.
Petitioners’ Answer with Counterclaim: Asserted Pedro Sr. left several parcels (240 sq. m TD No. 20814; 192 sq. m previously under TD No. 9534; agricultural land ~4 hectares). Claimed Pagmamana regarding the 240 sq. m lot was valid as a voluntary agreement among descendants; alleged respondents’ lawful share had been transferred through the 5 December 1968 Deed of Extrajudicial Settlement with Waiver (adjudicating the 192 sq. m lot to heirs of Pedro Jr.) and that the parties acquiesced to the arrangement, negating respondents’ cause of action.

Pre-trial, Trial, and Admissions

Pre-trial conference held 15 August 2000 where parties entered into stipulations, admissions, and identified issues for trial; those stipulations were reduced into the pre-trial record (Records pp. 70–71).
Key pre-trial admission by respondents: That the land covered by Tax Declaration No. 9534 (192 sq. m) previously owned by Pedro Sr. was transferred to Maria Constantino (respondents’ mother) under Tax Declaration No. 9535 — an admission treated as judicial and binding under Section 7, Rule 18, Rules of Court.
Trial testimony: Respondent Asuncion Laquindanum, when on the stand, denied ownership of the 192 sq. m lot by Pedro Sr. and testified vaguely that it was owned by Pedro Jr. and inherited by her mother Maria; the Court characterized this as a self-serving, unsupported declaration in light of pre-trial admissions.

RTC Decision (27 October 2003) — Findings and Rationale

RTC concluded both the 1968 Extrajudicial Settlement with Waiver and the 1992 Pagmamana were executed to the exclusion of certain heirs and that both plaintiffs (respondents) and defendants (petitioners) acted equally at fault (in pari delicto).
Applied doctrine of in pari delicto and related maxims and authorities (Yu Bun Guan v. Ong; Sarmiento v. Salud; LBC Express, Inc. v. Court of Appeals) to deny recovery to either party and to leave parties "where they are."
Found respondents as successors-in-interest and privies to the signatories of the 1968 deed (e.g., Maria Constantino), thus estopped from claiming otherwise (relying on Cabresos v. Tiro; Correa v. Pascual).
Dismissed plaintiffs’ complaint and counterclaims for damages for lack of valid factual and legal f