Case Summary (G.R. No. 154486)
Key Dates
- 1946: Alleged verbal business arrangement among heirs.
- 1948: Extrajudicial partition of parents’ real properties; proceeds partially used for education of younger heirs.
- April 29, 1957: “Acknowledgement of Participating Capital” executed by Conchita and Buenaventura Remotigue.
- 1973: Voluntary dissolution of the joint business arrangement.
- April 22, 1987: Antonieta filed amended complaint for accounting, partition, delivery of share, and damages.
- December 18, 1992: RTC Decision in favor of Antonieta, ordering delivery of 8% share in various properties and corporations plus damages and fees.
- July 30, 2002: Court of Appeals Decision limiting shares to three specified businesses.
- December 1, 2010: Supreme Court Decision affirming the Court of Appeals.
Applicable Law
- 1987 Philippine Constitution (decision post-1990).
- Rule 45, Rules of Civil Procedure (certiorari review on questions of law).
- Civil Code:
• Art. 1767—Partnership defined as contribution to a common fund with intent to divide profits.
• Art. 1769—Distinction between co-ownership and partnership.
• Art. 1797—Distribution of profits and losses according to agreement or contributions. - PD 1529, Sec. 48—Torrens titles not subject to collateral attack.
Facts
- Heirs of Andres Jarantilla and Felisa Jaleco partitioned real properties in 1948, allocating produce for certain heirs’ education.
- A joint business arrangement among heirs and spouses Deocampo and Remotigue generated profits and acquired assets until its 1973 dissolution.
- The 1957 “Acknowledgement of Participating Capital” listed capital contributions to three enterprises—Manila Athletic Supply (Manila), Remotigue Trading (Iloilo), and Remotigue Trading (Cotabato)—with Federico’s share at ₱5,000 (6%) and Antonieta’s at ₱8,000 (8%).
- In 1987, Antonieta sued for accounting and partition of all assets allegedly held in co-ownership; Federico later joined by compromise, claiming a 6% share.
Procedural History
- RTC approved the compromise and awarded Antonieta an 8% share in numerous real properties and corporations, plus moral damages (₱50,000), attorney’s fees (₱50,000), and costs.
- Both parties appealed.
- Court of Appeals held:
• Antonieta’s and Federico’s shares limited to the three businesses enumerated in the 1957 document.
• No partition or co-ownership of other corporations or real properties. - Petitioner filed a Rule 45 petition before the Supreme Court, raising only questions of law.
Issue
Whether petitioner is entitled to a 6% share in real properties allegedly acquired with funds from the unregistered partnership reflected in the 1957 Acknowledgement of Participating Capital.
Supreme Court’s Analysis
- Rule 45 confines review to questions of law; factual findings of RTC and CA stand unless clearly erroneous.
- Partnership requires intent to divide profits and a common fund (Art. 1767); mere co-ownership or sharing of returns does not establish a partnership (Art. 1769).
- The 1957 document unambiguously limited partnership assets to three specified enterprises; petitioner’s 6% share must likewise be confined to those enterprises under Art. 1797.
- No clear evidence that partnership funds purchased the subject real proper
Case Syllabus (G.R. No. 154486)
Facts of the Case
- The spouses Andres Jarantilla and Felisa Jaleco had eight children: Federico Sr., Delfin, Benjamin, Conchita, Rosita, Pacita, Rafael, and Antonieta.
- Petitioner Federico Jarantilla, Jr. is a grandson of Andres and Felisa through their son Federico Sr. He has two brothers, Doroteo and Tomas.
- In 1948, the Jarantilla heirs executed an extrajudicial partition of their parents’ real properties; the produce of some parcels (1947–1949) was allocated to fund Rafael’s and Antonieta’s studies.
- In the same year, a joint‐business arrangement arose among Rosita Jarantilla–Deocampo and Vivencio Deocampo, and Buenaventura Remotigue and Conchita Jarantilla, resulting in successful ventures and acquisition of properties and buildings.
- The partnership was formally dissolved in 1973 by mutual agreement.
- On April 29, 1957, the Remotigue spouses executed an Acknowledgement of Participating Capital, enumerating co‐owners and their contributions to three enterprises: Manila Athletic Supply (Manila), Remotigue Trading (Iloilo), and Remotigue Trading (Cotabato).
Procedural History
- April 22, 1987: Antonieta Jarantilla filed an amended complaint for accounting, partition, delivery of an 8% share, and damages (Civil Case No. Q-50464, RTC Quezon City, Branch 98).
- Respondents denied the 1946 partnership with Antonieta, acknowledged only the 1957 document’s scope, and relied on Torrens titles.
- During trial, petitioner entered into a compromise adopting Antonieta’s claims and asserting his own 6% interest.
- March 25, 1992: RTC approved the compromise.
- December 18, 1992: RTC rendered judgment awarding Antonieta 8% of specified real properties and corporate shares, plus damages and attorney’s fees; did not explicitly grant petitioner his 6% share.
- Both sides appealed to the Court of Appeals (CA-G.R. CV No. 40887).
- July 30, 2002: Court of Appeals set aside the RTC decision in part, limited Antonieta’s 8% to the three enu