Case Summary (G.R. No. 211153)
Factual Background
Heirs of Felix and Felisa Cruz inherited a 940-sqm property. In 1986, co-heirs executed a deed of extrajudicial settlement allocating two lots to Antonia Cruz and one lot to each sibling, despite an understanding of equal shares. Respondents discovered in 1998, during subdivision, that Antonia’s share exceeded theirs. Concepcion, a Grade 3 elementary graduate, alleged she was induced to sign the English-language settlement without explanation, depriving her of informed consent.
RTC’s Findings
The RTC held that the action was not barred by prescription but dismissed the complaint for insufficient proof of fraud. It found that Concepcion could read English sufficiently, had ten years to assert rights, and that traditions of unequal distribution to preserve peace were permissible. The court deferred to the notarized document’s presumption of regularity and noted Concepcion’s long silence and subsequent acquiescence.
CA’s Rationale
The CA characterized the action as one to annul the voidable settlement due to vitiated consent. It applied Civil Code Art. 1332 to invoke a presumption of mistake from Concepcion’s illiteracy and the English-only document. Finding no proof that the deed’s terms had been explained in Filipino, the CA held her consent neither intelligent nor voluntary. It applied the four-year prescriptive period for annulment actions, counting from discovery in 1995, and ruled the petition timely.
Issues Presented
- Whether the action to annul the extrajudicial settlement prescribed.
- Whether contemporaneous acts and silence negate fraud or vitiation of consent.
Petitioners’ Contentions
Petitioners argue that the ten-year period under Civil Code Art. 1144 applies to written contracts, rendering the 1998 complaint time-barred. They contend that Concepcion’s alleged illiteracy is contradicted by judicial notice of educational attainment and that the notarized deed’s integrity requires clear-and-convincing proof to set aside. They urge deference to the RTC’s factual findings.
Respondents’ Contentions
Respondents maintain that the settlement was designed to defraud Concepcion—an English-illiterate heir—thus invoking Civil Code Arts. 24 and 1332. They assert that the four-year annulment period applies from the discovery of fraud, and that their action filed in 1998 was timely. They stress the absence of proof that the deed’s contents were explained in a language Concepcion understood.
Supreme Cour
...continue readingCase Syllabus (G.R. No. 211153)
Procedural History
- Petition for Review on Certiorari under Rule 45 was filed before the Supreme Court assailing the June 25, 2013 Decision and January 29, 2014 Resolution of the Court of Appeals in CAA G.R. CV. No. 96345.
- The Court of Appeals had granted respondents’ appeal, reversed the June 1, 2010 Decision of the Regional Trial Court (RTC) of San Mateo, Rizal, Branch 75, and denied petitioners’ motion for reconsideration.
- This Court, in a November 9, 2015 Resolution, gave due course to the petition and subsequently resolved to deny it.
Factual Antecedents
- The parties are seven children of Felix and Felisa Cruz: Angelito, Concepcion, Serafin, Vicente, Amparo, Antonia (deceased), and petitioner heirs of Antonia (Ernesto Halili et al.).
- The subject property is a 940-sqm parcel covered by Original Certificate of Title No. ON-658.
- On July 31, 1986, the siblings executed a Deed of Extrajudicial Settlement of Estate, agreeing in writing to equal partition of the property.
- In 1998, during subdivision, respondents discovered that Antonia was allotted two lots while each of the other heirs received only one.
- Respondents alleged that Amparo and Antonia perpetrated fraud by presenting the English-language settlement to illiterate Concepcion, failing to explain its contents before securing her signature.
- Antonia’s two lots passed to her heirs—Ernesto Halili et al.—who remained in possession thereof.
- Respondents prayed for: (1) nullity of the July 31, 1986 settlement; (2) return of one of Antonia’s lots to the common fund; (3) just and equitable relief; and (4) costs of suit.
- Petitioners answered, contending free consent, prescription, failure to state a cause of action, lack of compromise efforts, and counterclaimed for moral/exemplary damages, attorney’s fees, and costs.
Ruling of the Regional Trial Court
- The RTC held that the action was not barred by the ten-year prescription under Article 1144 nor by laches.
- It found that fraud must be pleaded with particularity (Sec. 5, Rule 8) and proved by clear and convincing evidence.
- Concepcion, though of limited education, was deemed capable of understanding the instrument and, having lived with the consequences for over ten years, could not feign ignorance.
- Notarization gave the settlement the character of a public document, prevailing over mere allegations.
- Subsequent acquiescence—house constru