Case Summary (G.R. No. L-55225)
Factual Background
The complaint asserts that Braulio Jardin and Maura Hallasgo were the parents of Catalino and Galo, while Sixto Hallasgo was Maura's child by a previous union. In 1920, a private partition divided inherited properties among the three heirs. The complaint includes specific assets outlined in this partition, specifying the sizes and values of various parcels of land, such as residential lots, cornland, and riceland, distributed between the heirs.
Allegations of Usurpation
Following the partition, Galo later transferred his share of a city lot to Catalino, leading to Catalino's ownership of a 990-square-meter residential lot. In 1963, Sixto was permitted to cultivate a garden on a 350-square-meter portion of this lot. However, it is claimed that in 1964, Sixto fraudulently included the same area in his cadastral survey without notifying Catalino's heirs, subsequently occupying lands that belonged to Galo and Catalino without providing any harvest shares to them.
Legal Proceedings and Dismissal
In 1973, the children of Galo and Catalino became aware of the partition, after which they filed their complaint seeking reconveyance of the properties and damages. Defendants Hallasgo submitted a motion to dismiss the complaint, which was granted by the trial court on grounds of prescription. The plaintiffs appealed, asserting their action had not prescribed and contesting the dismissal's factual basis.
Prescription and Legal Principles
The plaintiffs argued that the partition among co-heirs does not expire, and the possession of community property by one co-owner should not be regarded as adverse to the other co-owners. However, the court found these arguments lacking in substance, as the complaint failed to provide essential facts including the dates of death of the heirs, the specific date Sixto allegedly usurped the properties, and why the heirs did not act earlier.
Court's Analysis of Partition Validity
The court held that the 1920 partition had indeed been executed, with specific lands adjudicated to Galo and Catalino. Thus, Sixto could not have unlawfully usurped lands that were distinctly partitioned. The court determined the existence of co-ownership only concerning a few specific properties, while recognizing that Sixto’s acknowledgement of the co-ownership had been severed by his actions.
Additional Legal Considerations
Notably, Article 494 of the Civil Code stipulates that co-owners are not bound to remain in co-ownership indefinitely, and that actions for partition may be barred by prescription under certain conditions. The trial court rightly assumed that the prescription commenced even before the Civil Code took effect, leading them to conclude that the plaintiffs’ action was time-barred.
Recovery of 350-square-meter Portion
Conversely, the court identified that
...continue readingCase Syllabus (G.R. No. L-55225)
Case Background
- The case revolves around the enforcement of a 1920 partition of unregistered lands, initiated by the heirs of Catalino Jardin and Galo Jardin against the heirs of Sixto Hallasgo in 1973.
- The spouses Braulio Jardin and Maura Hallasgo had two children, Catalino and Galo, alongside Sixto Hallasgo, who is the child of Maura from her first marriage.
- In 1920, the three heirs partitioned various properties inherited from their parents through a private document.
Properties Involved in the Partition
- The partition included multiple parcels of land, each assigned specific areas and assessed values:
- Residential Lot in Jasaan (2 x 495 sqm to Catalino and Galo, remainder to Sixto).
- Cornland at Barrio Camposanto (7.5 gantas allocated between Sixto, Catalino, and Galo).
- Additional lands in Barrio Cabagtucan, Canajawan, and Sagpolon with varying sizes and valuations.
- The partition also involved a cow and a strong materials house.
Subsequent Transactions
- Galo ceded his share of the poblacion lot (495 sqm) to Catalino in exchange for Catalino’s share of riceland in Barrio Sagpolon, resulting in Catalino owning 990 sqm of the lot.
Sixto's Occupation and Usurpation
- In 1963, Sixto was allowed to use a 350 sqm portion of the lot owned by Catalino's children as a garden.
- In 1964, Sixto fraudulently included this portion in the cadastral survey of his share without informing Catalino's children.
- Sixto and his h