Case Summary (G.R. No. 121157)
Background of the Dispute
The petitioners assert that they along with the respondents co-own the disputed parcels of land. The respondents, however, maintain that their father, Roque Bauzon, was the rightful owner due to a deed of donation propter nuptias. The family dynamic is complicated by the fact that Roque and the petitioners are descendants of Ramon Bauzon y Untalan, who passed away intestate in 1948. The petitioners allege that Roque repudiated their co-ownership and transferred the lands to his children without their knowledge.
Trial Court Proceedings
The trial court found that the properties in question form part of the estate of Ramon Bauzon and his wife, Sotera Zulueta. The court concluded that the land devolved upon the children equally as co-owners. However, it awarded the properties to Segunda Maningding and Roque Bauzon, citing affidavits executed by Juan and Maria Maningding which renounced their shares in favor of Roque. The court rejected the claim of donation due to lack of evidence for its execution and ruled against Roque’s sales of the properties to his children.
Court of Appeals Decision
The Court of Appeals initially affirmed Roque's ownership based on the donation propter nuptias but later nullified this deed due to non-compliance with the formal requirements prescribed by Article 633 of the old Civil Code, which necessitated a public instrument for validity. However, the court maintained that Roque acquired the lands through acquisitive prescription, arguing that his continuous and adverse possession for over thirty years sufficed despite the technicalities surrounding the donation.
Acquisitive Prescription
The concept of acquisitive prescription was pivotal to the appeals court's decision. The court elucidated that ownership could be acquired through either ordinary or extraordinary prescription, with the latter requiring uninterrupted adverse possession for thirty years. The properties in question were unregistered but were previously declared for tax purposes in the name of Ramon Bauzon.
Legal Basis of Possession
The appellate court underscored that even in the absence of a formally executed donation, the private document of donation could still serve as a basis for a claim of ownership, particularly when possession was evident and united with intent and conduct indicative of ownership. Roque Bauzon's continuous and uninterrupted use of the land for agricultural purposes was deemed robust evidence of ownership.
Impact of Laches
The court further noted the petitioners' delay in claiming their rights, labeling it as laches. They allowed a significant lapse of time—sixty years since the donation and thirty-six years since Roque's possession pos
...continue readingCase Syllabus (G.R. No. 121157)
Case Background
- This case concerns an action for annulment of documents, accounting, and partition of two parcels of land, specifically a riceland and a sugarland located in Calasiao, Pangasinan.
- Petitioners claim co-ownership of the disputed properties alongside private respondents Luis and Eriberta Bauzon.
- The respondents assert ownership through a deed of donation propter nuptias from their father, Roque Bauzon.
Parties Involved
- Petitioners: Heirs of Segunda Maningding, including Delfin, Gil, Emma, Manuel, Racquel, Ester, Remedios, and Jessie Parayno, along with Maxima Parayno, Leonardo Parayno, and Felicisim Parayno.
- Respondents: Court of Appeals and heirs of Roque Bauzon, specifically Luis Bauzon and Eriberta Bauzon (deceased), represented by her husband Placido Zulueta, and Jose Parayno.
Ownership Claims and Background
- Roque Bauzon, along with Juan and Maria Maningding, were children of Ramon Bauzon y Untalan who died intestate in 1948.
- Petitioners contend that Roque repudiated co-ownership of the sugarland in 1965 and that Juan and Maria Maningding executed a quitclaim regarding the riceland in 1970.
- Roque Bauzon subsequently transferred the riceland to Luis Bauzon and the sugarland to Eriberta Bauzon.
Discovery of Transfers
- The heirs of Segunda Maningding discovered the transfers made by Roque Bauzon in favor of his children only in 1986.
- Attempts to partition the properties and seek an accounting of the produce were unsuccessful.
Contesting Claims
- Private respondents argue that Segunda