Case Summary (G.R. No. 202578)
Petitioner
Heirs of Gilberto Roldan (Adelina Roldan, Rolando Roldan, Gilberto Roldan Jr., Mario Roldan, Danny Roldan, Leonardo Roldan, Elsa Roldan, Erlinda Roldan-Caraos, Thelma Roldan-Masinsin, Gilda Roldan-Dawal, Rhodora Roldan-Icamina)
Respondent
- Heirs of Silvela Roldan (Antonio R. De Guzman, Augusto R. De Guzman, Alicia R. Valdoria-Pineda, Sally R. Valdoria)
- Heirs of Leopoldo Magtulis (Cynthia Yorac-Magtulis, Lea Joyce Magtulis-Malaborbor, Dhancy Magtulis, Frances Diane Magtulis, Julierto Magtulis-Placer)
Key Dates
- 1961: Death of Natalia Magtulis and exclusive possession by Gilberto’s heirs
- May 19, 2003: Complaint for Partition and Damages filed with the RTC
- December 14, 2007: RTC Decision declaring three equal co-owners
- December 20, 2011: CA Decision affirming RTC
- September 27, 2017: Supreme Court Decision
Applicable Law
- 1987 Philippine Constitution
- Family Code Articles 172 and 175 (filiation)
- Civil Code Article 494 (prescription among co-owners)
- Rule 45, Rules of Court (scope of certiorari review)
Facts of the Case
Upon Natalia’s death in 1961, her heirs Gilberto and Silvela each inherited an undivided one-half of Lot No. 4696; Leopoldo’s status as a child of Natalia was disputed. Gilberto’s heirs occupied the entire property, excluding respondents. In 2003, respondent heirs sued for partition and damages. Petitioners alleged that Silvela sold her share to Gilberto and that Leopoldo was not Natalia’s child.
Procedural History
The RTC found no evidence of sale by Silvela and held that Leopoldo’s baptismal and marriage certificates proved his filiation to Natalia, ordering three equal shares. The CA affirmed. Petitioners filed for reconsideration and then a Rule 45 petition for review on certiorari.
Issues
- Did Silvela sell her share to Gilberto?
- Was Leopoldo proven to be Natalia’s child?
- Do prescription and laches bar respondents from claiming co-ownership?
Sale of Silvela’s Share
A contract of sale is a question of fact. Neither the RTC nor the CA found any document or credible witness to prove that Silvela conveyed her rights to Gilberto. Under Rule 45, factual findings duly supported by evidence are final. Petitioners’ unsupported allegations do not overcome the presumption of co-ownership.
Filiation of Leopoldo to Natalia
Legitimate or illegitimate filiation under Family Code Articles 172 and 175 is normally established by birth records or public admissions. A baptismal certificate and a marriage contract—both prepared without Natalia’s participation—have very limited probative value on parentage. Jurisprudence (Fernandez v. CA; Macadangdang v. CA; Paa v. Chan) holds that these documents alone cannot prove filiation. No additional evidence (testimonial, pictorial, or documentary) was presented. Thus, Leopoldo’s status as a child of Natalia was not sufficiently established.
Prescription and Laches
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Facts of the Case
- Natalia Magtulis owned Lot No. 4696, an agricultural parcel of 21,739 sqm in Kalibo, Aklan, covered by Original Certificate of Title No. P-7711.
- She had three children: Gilberto Roldan and Silvela Roldan (from her first marriage) and Leopoldo Magtulis (allegedly from another relationship).
- Upon Natalia’s death in 1961, Gilberto and his heirs took exclusive possession of the lot, excluding Silvela’s and Leopoldo’s descendants.
- On May 19, 2003, the heirs of Silvela and Leopoldo filed a Complaint for Partition and Damages in the RTC against the heirs of Gilberto.
- Petitioners (heirs of Gilberto) defended on two grounds:
- That Silvela had previously sold her share to Gilberto.
- That Leopoldo was not Natalia’s child and thus had no cause of action.
Procedural History
- RTC, Branch 8, Kalibo, Aklan (Dec. 14, 2007):
- Found no proof of sale by Silvela; held her heirs still co-owners.
- Relied on Leopoldo’s baptismal certificate and marriage contract to recognize his filiation to Natalia.
- Declared three co-owners (heirs of Gilberto, Silvela, Leopoldo), each entitled to one-third shares; ordered accounting and delivery of produce.
- CA, Fourth Division (Dec. 20, 2011):
- Affirmed RTC’s findings on both sale and filiation.
- Denied petitioners’ Motion for Reconsideration (June 1, 2012).
- Petition for Review on Certiorari filed before the Supreme Court (July 6, 2012).
Issues Presented
- Whether Silvela sold her share of Lot No. 4696 to Gilberto.
- Whether Leopoldo is Natalia’s child based on his baptismal and marriage certificates.
- Whether prescription and laches bar the responde