Case Summary (G.R. No. 217611)
Petitioner’s Claim and Legal Basis
Petitioner alleged co-ownership of the eight parcels based on his inclusion as a vendee in the notarized Deed of Absolute Sale (April 14, 1987) and his name appearing in the eight TCTs issued May 19, 1987. He invoked Article 494 of the Civil Code, asserting the right to demand partition at any time because no agreement to keep the properties undivided existed.
Respondents’ Contentions
Respondents Azares denied that petitioner is a co-owner, asserting he never contributed to acquisition or maintenance and was incapable of purchasing the properties owing to his status as an employee. They maintained that the Azares purchased the properties to provide a place for employees/relatives to live and that any inclusion of others in the documents was for convenience or as a trust arrangement. Some respondents either did not contest partition or did not answer.
Procedural History
RTC, Branch 30, Tagum City: dismissed petitioner’s complaint for partition (Decision dated February 27, 2012). Court of Appeals (Cagayan de Oro City), Special 21st Division: affirmed the RTC (Decision dated July 30, 2014; Motion for Reconsideration denied February 26, 2015). Supreme Court: petitioner filed a Petition for Review on Certiorari under Rule 45; Supreme Court rendered the dispositive ruling reversing the lower courts (decision promulgated March 27, 2019).
Applicable Law and Constitutional Basis
Applicable Constitution: 1987 Philippine Constitution (decision date post-1990). Key statutory and doctrinal bases applied by the Court: Article 494 of the Civil Code (right to partition), Rule 69 of the Rules of Court (partition procedure), recognized doctrines on indefeasibility of Torrens titles, presumptions as to public documents and notarized deeds (Rule 132, Sec. 23), and principles governing proof of trusts and the probative value of tax declarations versus certificates of title.
Central Issue
Whether the Court of Appeals correctly upheld the RTC’s finding that petitioner Logrosa is not a co-owner but only a trustee/occupant, thereby justifying dismissal of his complaint for partition.
Supreme Court Holding
The Supreme Court granted the petition. It held that the evidence on record sufficiently established petitioner Logrosa’s co-ownership of the subject properties. The CA and RTC decisions were reversed and set aside, and the RTC was directed to issue an order under Rule 69 for partition of the properties.
Reasoning: Prima Facie Effect of Titles and Deed
The Court emphasized the strong legal presumption that a certificate of title is evidence of an indefeasible and incontrovertible title in favor of the person named therein; likewise, a duly notarized deed of sale is a public document entitled to a presumption of validity as to authenticity and due execution. Because petitioner’s name appeared in eight TCTs and in the notarized Deed of Absolute Sale as a co-vendee, a prima facie case of co-ownership existed and the burden shifted to respondents to prove otherwise.
Reasoning: Insufficiency of Respondents’ Evidence
Respondents relied primarily on the self-serving testimony of Cesar Azares asserting that others were included in the titles only for convenience or as occupants/trustees, and pointed to tax declarations and tax payments as evidentiary support. The Court found this insufficient to overcome the strong presumption in favor of petitioner: a solitary, self-serving testimony cannot displace the probative weight of public documents. Tax declarations and receipts cannot prevail over TCTs absent additional convincing evidence, and respondents did not provide such corroboration.
Reasoning: Possession, Conduct, and Admissions
The Court noted that petitioner’s possession of a portion of the property without opposition, the long delay (more than two decades) by respondents in asserting sole ownership, and specific admissions by respondent Cesar (stating an intention to give houses and land to occupants) strengthened the finding of co-ownership. The Court described respondents’ conduct and lack of protective measures (e.g., executing documents asserting sole ownership) as inconsistent with a bona fide claim of exclusive ownership.
Reasoning: Trust Allegations and Capacity to Purchase
The Court reiterated that the party asserting a trust bears the
...continue readingCase Syllabus (G.R. No. 217611)
Procedural Posture
- Petition for Review on Certiorari under Rule 45 of the Rules of Court filed by petitioner Rogelio Logrosa (petitioner Logrosa) attacking the Court of Appeals (CA) Decision dated July 30, 2014 and Resolution dated February 26, 2015 in CA-G.R. CV No. 02878-MIN.
- Underlying case: Civil Case No. 4026, Regional Trial Court (RTC), Tagum City, Davao del Norte, Branch 30 — complaint for partition filed by petitioner Logrosa.
- RTC rendered a Decision dated February 27, 2012 dismissing the complaint for lack of merit.
- Petitioner Logrosa appealed to the CA; the CA denied the appeal and affirmed the RTC in its Decision dated July 30, 2014. Petitioner filed a Motion for Reconsideration dated August 22, 2014, which the CA denied in its Resolution dated February 26, 2015.
- The instant Petition to the Supreme Court followed. Respondents Sps. Azares filed a Comment (July 17, 2017); petitioner filed a Reply (November 29, 2017).
Parties
- Petitioner: Rogelio Logrosa.
- Respondents: Spouses Cleofe and Cesar Azares (collectively, respondents Sps. Azares); Spouses Abundio, Jr. and Antonieta Dumagan Torres (collectively, respondents Sps. Torres); Spouses Nelson Sala and Arlene Ang (collectively, respondents Sps. Sala); Spouses Bonifacio, Jr. and Welhelmina Baruiz (collectively, respondents Sps. Baruiz).
Subject Properties and Titles
- Eight parcels of land situated in the Municipality of Tagum (now Tagum City), Davao del Norte, described under the following Transfer Certificates of Title (TCTs): TCT No. T-52508, TCT No. T-52509, TCT No. T-52510, TCT No. T-52511, TCT No. T-52512, TCT No. T-52513, TCT No. T-52514, and TCT No. T-52515.
- The aforementioned TCTs indicate that petitioner Logrosa, together with the respondents, are co-owners of the subject properties.
Deed of Absolute Sale (April 14, 1987) and Issuance of Titles
- A duly notarized Deed of Absolute Sale dated April 14, 1987 was executed by the original owner Benjamin A. Gonzales and the vendees, bearing the signatures of Gonzales, petitioner Logrosa, and respondents Cleofe, Nelson, Bonifacio, and Abundio.
- The records show that the titles were issued to the parties on May 19, 1987.
- The Deed of Absolute Sale is not denied by respondents Sps. Azares as to petitioner Logrosa’s status as a co-vendee; respondent Cleofe was a co-signatory.
Petitioner's Claim and Legal Basis for Relief
- Petitioner asserted that he and the respondents are co-owners of the eight parcels and that co-ownership had existed for more than ten (10) years without any subsequent agreement to keep the properties undivided.
- He grounded his complaint for partition on Article 494 of the New Civil Code: "No co-owner shall be obliged to remain in the co-ownership. Each co-owner may demand at any time the partition of the thing owned in common, insofar as his share is concerned."
Pleadings and Responses of Parties
- Only respondents Sps. Azares filed an Answer, opposing the partition and disputing petitioner’s status as co-owner, alleging he never contributed to acquisition, maintenance, or taxes.
- Respondents Sps. Torres and respondent Welhelmina filed manifestations stating they would not file answers and interposed no objection to partition.
- Respondents Sps. Sala did not file any answer.
Trial Evidence Presented
- Petitioner Logrosa testified in support of his claim and presented respondent Antonieta to identify documents related to the acquisition.
- Respondents Sps. Azares presented one witness: respondent Cesar Azares, who denied that petitioner and the other respondents were made co-owners and asserted they were merely employees lacking capacity to acquire the properties.
- Evidence included: the notarized Deed of Absolute Sale (April 14, 1987), the eight TCTs, tax declarations and receipts (presented by respondents Sps. Azares), and receipts and documents presented by respondent Abundio (including official receipt of tax payment, a tax declaration naming Cleofe, Abundio, Nelson, and petitioner Logrosa, and Owner’s Duplicate Copies of TCT Nos. T-52510 and T-52508).
RTC Decision (February 27, 2012)
- The RTC dismissed petitioner Logrosa’s complaint for partition for lack of merit. (Decision penned by Presiding Judge Rowena Apao-Adlawan.)
CA Decision and Resolution (July 30, 2014; February 26, 2015)
- The Court of Appeals, Special Twenty-First Division, denied petitioner Logrosa’s appeal and affirmed the RTC in its Decision dated July 30, 2014, holding that the evidence adduced by petitioner was insufficient to warrant a positive finding of co-ownership.
- The CA denied petitioner Logrosa’s Motion for Reconsideration in its Resolution dated February 26, 2015.
- The CA Decision was penned by Associate Justice Oscar V. Badelles, with Associate Justices Romulo V. Borja and Pablito A. Perez concurring.
Central Issue Before the Supreme Court
- Whether the CA was correct in upholding the RTC’s dismissal of petitioner Logrosa’s complaint for partition on the ground that petitioner is not a co-owner but merely a trustee of the subject properties.
Legal Presumptions and Authorities Considered by the Supreme Court
- The certificate of title serves as