Case Summary (G.R. No. 57062)
Background and Factual Summary
Lupo Mariategui died without a will, having entered into three marriages sequentially. From his first marriage to Eusebia Montellano, he sired four children, two of whom left descendants. His second marriage to Flaviana Montellano bore a daughter, Cresenciana. With his third wife, Felipa Velasco, whom he married around 1930, Lupo had three children: Jacinto, Julian, and Paulina. Felipa died in 1941. The decedent left several real properties acquired while he was unmarried, including certain lots in the Muntinglupa Estate.
The descendants from the first and second marriages executed an extrajudicial partition on December 2, 1967, adjudicating Lot No. 163 to themselves, which was later registered under their names through Torrens title (OCT No. 8828) in 1971. The lots were thereafter subdivided and transferred individually. The children from the third marriage (Jacinto, Julian, and Paulina) filed a complaint in 1973 denying their exclusion and asserting their rights to inherit a portion of Lot No. 163 as well as other lots, praying for partition and annulment of the earlier extrajudicial partition deed.
Legal Issues Presented
The petitioners questioned:
(a) Whether prescription barred the respondents’ right to demand partition of their father's estate.
(b) Whether the respondents effectively proved legal recognition and succession rights over the estate given their alleged belated filing and lack of documentary proof of legitimacy.
Nature of the Complaint and Cause of Action
The Court emphasized that the primary relief sought by the respondents was partition of the estate, with the allegation of legitimate filiation raised only to support their claim as heirs. The nature of an action is determined by the facts constituting the cause of action rather than merely the relief prayed for. The respondents’ case was essentially an action for partition of co-owned property.
Marriage and Legitimacy of Respondents under Philippine Law
The Court of Appeals, affirmed by the Supreme Court, held that the marriage between Lupo Mariategui and Felipa Velasco was presumptively valid although no marriage certificate was produced. This was supported by testimony that Lupo had declared the existence of this marriage, the couple’s public acknowledgment as husband and wife, and their community’s recognition of their status. Under the legal presumption recognized in Philippine jurisprudence, cohabitation and public representation as husband and wife establish a valid marriage in the absence of contrary evidence.
In light of the 1987 Philippine Constitution and the Family Code of the Philippines, only two classes of children now exist: legitimate and illegitimate. The legitimacy of children is established by birth records, final judgments, or open and continuous possession of the status of legitimate children. Here, Jacinto’s birth certificate established his legitimacy, while Julian and Paulina’s continuous possession of legitimate status sufficed to prove theirs.
Prescription and Rights to Partition
Prescription under Article 285 of the Civil Code, concerning actions for recognition of paternity, was deemed inapplicable to this case because the respondents were found to be legitimate children, thus entitled to inheritance rights without the need for formal recognition.
Furthermore, the Court held that an action to demand partition of co-owned property is imprescriptible; it cannot be barred by prescription or laches unless there has been a valid and clear repudiation of co-ownership by the co-owner expressly communicated to the others. The partition action thus remained viable because the co-ownership had not been effectively repudiated.
Effect of Extrajudicial Partition and Property Registration
Although petitioners executed an extrajudicial partition and obtained Torrens titles solely in their names, such acts did not amount to valid repudiation of co-ownership vis-à-vis the respondents. Owners’ registration of property under the Torrens system constitutes constructive notice of ownership but does not give shelter to fraud or allow the extinguishment of others’ rights in the property without proper repudiation. The respondents promptly filed their partition action in 1973, shortly after becoming aware of the registration, thus preserving their rights.
Final Ruling and Legal Reasoning
The Supreme Court affirmed the Court of Appeals decision, holding that:
- The responde
Case Syllabus (G.R. No. 57062)
Case Background and Parties Involved
- The case involves a petition for review on certiorari filed by Maria del Rosario Mariategui and others (petitioners) against the Court of Appeals, with respondents being Jacinto Mariategui, Julian Mariategui, and Paulina Mariategui.
- The controversy arises over the inheritance and partition of properties left by the deceased Lupo Mariategui.
- Lupo Mariategui died intestate on June 26, 1953, after contracting three marriages during his lifetime.
- He had four children with his first wife, Eusebia Montellano (deceased 1904), a daughter with his second wife, Flaviana Montellano, and three children with his third wife, Felipa Velasco.
- The properties involved include several lots of the Muntinglupa Estate, acquired by Lupo while unmarried.
- The first and second marriage descendants executed an extrajudicial partition deed in 1967 for Lot No. 163 and obtained Torrens titles thereafter.
- The third marriage children filed suit in 1973 to assert their rights and claimed deprivation of their respective shares in the estate.
Facts on Marriage, Children, and Property Ownership
- Lupo’s third marriage to Felipa Velasco allegedly took place around 1930.
- There are three children from the third marriage: Jacinto (b. 1929), Julian (b. 1931), and Paulina (b. 1938); Felipa died in 1941.
- The lots subject to dispute include Lots Nos. 163, 669, 1346, and 156 of the Muntinglupa Estate.
- Descendants from first and second marriages partitioned and obtained titles for Lot 163, subdividing it into smaller lots with separate titles.
- The children of the third marriage claimed their shares in the estate and sought annulment of the extrajudicial partition for excluding them.
Procedural History and Motions
- The petitioners filed an answer with a counterclaim and motion to dismiss based on lack of cause of action and prescription.
- The lower court initially denied the motion to dismiss in 1974 but ultimately dismissed the complaint and counterclaim in 1977, citing insufficient proof of recognition or legitimate filiation.
- The third marriage children elevated the case to the Court of Appeals, challenging the lower court's ruling on their legitimacy and inheritance rights.
- The Court of Appeals reversed the lower court in 1980, recognizing all children and descendants as entitled to equal shares, ordering reconveyance or reimbursement, and directing a partition project.
Issues Presented for Resolution
- The core issues presented to the Supreme Court were:
- Whether prescription barred the respondents' right to demand partition of the estate.
- Whether respondents, who filed the action belatedly, proved their successorial rights.
- A preliminary question was the precise nature of the complaint: whether it was an action for recognition