G.R. No. 132518 - Maglucot-Aw vs. Maglucot

In 1952, the Court of First Instance (CFI) of Negros Oriental issued an order to subdivide Lot No. 1639 into six portions, designated as Lot 1639-A to Lot 1639-F.
Lot 1639-D was allocated to Roberto Maglucot, who subsequently rented portions of this lot to Guillermo, Leopoldo, and Severo Maglucot, who built houses on their respective leased lots.
In 1992, the lessees ceased rental payments, claiming ownership of Lot 1639-D, arguing that no valid partition occurred due to the absence of a confirmed subdivision plan.

The Regional Trial Court (RTC) ruled that a valid subdivision of Lot 1639 had occurred, affirming the petitioners' ownership of Lot 1639-D.
The Court of Appeals (CA) reversed this decision, stating that the absence of a confirmed subdivision plan invalidated the partition, leading to the petition for review.

The Court noted that the parties did not object to the Order of Partition and had acted in a manner that indicated their acceptance of it over a span of more than 40 years.
The respondents' long-term occupation of their respective lots, in accordance with the subdivision plan, precluded them from later contesting the binding nature of the partition.

The payment of rentals by the respondents indicated their status as lessees rather than owners, establishing that their possession of Lot 1639-D was as holders, not as owners.

The Supreme Court emphasized that its jurisdiction in cases from the CA is limited to reviewing errors of law, with findings of fact from the CA generally being conclusive unless specific exceptions apply.
The exceptions include situations where findings are based on speculation, manifestly mistaken inferences, grave abuse of discretion, or misapprehension of facts.

An action for partition consists of two phases:
1. Determining the existence of co-ownership and whether partition is appropriate.
2. Confirming the subdivision plan when parties cannot agree on partition.
The first phase can conclude with a declaration of co-ownership or a ruling against partition.

An order for partition is considered final and appealable if it resolves the rights of the parties regarding the property in question.
The Court noted that parties who do not object to an interlocutory decree and act in accordance with it cannot later challenge its validity.

Parties who accept their allotted portions in a partition are estopped from questioning the title to portions assigned to others.
A person cannot simultaneously claim under and against the same instrument, necessitating acceptance of the partition in its entirety.

Technical estoppel requires that a party knowingly misleads their adversary, who then relies on that action.
Ratification can occur when a party, aware of their right to repudiate a defective proceeding, chooses to adopt it, thus binding themselves to its terms.

Partition can be inferred from strong circumstantial evidence, such as long-term possession and improvements made on the land.
The absence of formal documentation does not negate the existence of a partition if the parties have acted in accordance with it.

The absence of an annotation in the certificate of title does not invalidate a partition, as registration serves primarily to notify third parties.
Non-registration does not relieve parties of their obligations under a partition agreement.

The petitioners presented evidence, including tax declarations, indicating that the respondents acknowledged the ownership of Lot...continue reading