G.R. No. L-44664 - Mendoza I vs. Court of Appeals

Case Summary (G.R. No. L-44664)

Factual Background

Petitioners instituted an action for reconveyance of real property before the Court of First Instance of Bulacan on February 18, 1969 against respondents spouses Renato Samonte and Lucia de la Cruz Samonte. Petitioners alleged their status as legal heirs of Arcadio Mendoza and described Trinidad Manuel Mendoza as the surviving spouse of Arcadio Mendoza, with the rest of petitioners as legitimate children of Arcadio Mendoza and Trinidad Manuel. Arcadio Mendoza died on November 4, 1944, leaving multiple parcels of land, including property covered by Original Certificate of Title No. 12192.

Lot 3-A—the portion later sold—is described as a defined segment of Lot 3, with specific metes and bounds and technical data. Petitioners’ theory rested on the claim that Arcadio Mendoza’s estate had never been effectively partitioned such that Trinidad Manuel could not validly convey a determinate portion by metes and bounds to a third party. In their First Amended Complaint, filed on October 27, 1970, petitioners added that if the sale were declared valid, they were nonetheless entitled to legal redemption.

In pre-trial on June 28, 1971, the parties adopted partial stipulations of fact. Among them were that Arcadio Mendoza acquired ownership over the land through donation from Jose Samonte, and that the lot in controversy—Lot 3—was later subdivided into Lot 3-A and Lot 3-B. The stipulation then identified that on June 26, 1962, petitioner Trinidad Manuel Mendoza sold Lot 3-A to respondents. The stipulation quoted passages from the deed of sale, denominated in Tagalog as the “Dokumento ng Bilihan,” where Trinidad Manuel declared that Lot 3-A was her share by virtue of an agreement with her children and that she sold it to respondents with the corresponding consent and undertakings arising from that arrangement.

The deed also reflected that respondents’ improvements were introduced on the property after the sale, and the stipulation recorded that the deed was written in Tagalog, signed by Trinidad Manuel as vendor, witnessed by other petitioners (Juliana Mendoza and Pacita Mendoza Samonte), and notarized by Atty. Pedro Magsalin.

Trial Court Proceedings

On October 15, 1973, the trial court dismissed petitioners’ complaint with costs. The dismissal turned on the trial court’s finding that a partition agreement existed and that Lot 3-A had been effectively adjudicated to Trinidad Manuel prior to the sale, rendering the property no longer part of undivided co-ownership at the time of alienation. The trial court relied principally on the provisions of the “Dokumento ng Bilihan”, which it treated as admissions by petitioners involved in executing and witnessing the deed. It emphasized that paragraphs in the deed indicated an agreement among the heirs that Lot 3-A would be the share of Trinidad Manuel while Lot 3-B would belong to the children.

The trial court further reasoned that the subdivision of Lot 3 on September 7, 1961, as shown by the approved subdivision survey plan, corroborated the existence of the partition arrangement. It also considered the petitioners’ denials that they did not read or understand the deed’s contents. Although petitioners Trinidad Manuel, Pacita Samonte, and Juliana Samonte testified that they did not read or fully understand the document when they signed, the trial court concluded that such denials could not overcome the presumption that persons do not sign legal papers without understanding them, especially since the deed was written in Tagalog and petitioners testified in the Tagalog dialect. The trial court also noted that the deed was prepared by petitioners’ lawyer and that the deed was allegedly read to them before they signed.

A further circumstance weighed heavily on the trial court’s assessment of credibility: after the deed’s execution in 1962, respondents began constructing their house on the lot openly where petitioners resided. The trial court concluded that petitioners’ failure to stop or even question the construction indicated that they knew respondents had a right to build on the disputed property.

Having found that Lot 3-A was already adjudicated to Trinidad Manuel pursuant to a partition agreement, the trial court held that Article 1620—which allows legal redemption by co-owners—could not be applied because the alienated property was no longer held in co-ownership at the time of sale.

Appellate Review and Remaining Issues

The Court of Appeals affirmed the trial court’s decision, and later denied petitioners’ motion for reconsideration, prompting the present petition for review on certiorari.

The issues framed for resolution in the Supreme Court were whether (1) the “Dokumento ng Bilihan” was valid, and (2) petitioners could still exercise the right of legal redemption. Petitioners argued that Trinidad Manuel executed the deed on June 26, 1962, when Lot 3-A was allegedly still under litigation, and that the Court of Appeals’ earlier ruling in C.A.-G.R. No. 22891-R, dated September 23, 1964, had determined that Lot 3-A stemmed from Jose Samonte’s donation to Arcadio Mendoza. Petitioners contended that, because the donor-derived estate limited Trinidad Manuel’s share under Article 996, Trinidad Manuel could sell only her own proper fraction, and not more. Petitioners also maintained that since they did not execute any partition agreement, the deed was null and void insofar as it affected the interests of the other petitioners, and thus they remained entitled to redemption under Article 1620.

Respondents countered that Trinidad Manuel had declared under oath in the deed that Lot 3-A was awarded to her pursuant to an agreement of partition among her children. Respondents also argued that the deed showed that the sale occurred with the children’s knowledge and consent, with the consideration agreed upon and known. Respondents asserted that the Tagalog language used was consistent with the dialect spoken by petitioners in Bulacan, and that the deed was prepared and notarized by petitioners’ family lawyer. Respondents further invoked estoppel, contending that petitioners who participated in, consented to, and benefited from the sale could no longer impugn its validity.

Legal Basis and Reasoning

The Supreme Court addressed the first issue by resolving two sub-questions: whether Lot 3 had been partitioned and, if so, whether Lot 3-A had been adjudicated to Trinidad Manuel. The Court observed that petitioners’ co-ownership derived from intestate succession. It invoked Article 1078 of the Civil Code: where there were two or more heirs, the decedent’s whole estate was owned in common by the heirs before partition. The Court then reasoned that the co-ownership over Lot 3 was extinguished once the estate was subdivided into Lot 3-A and Lot 3-B, because the portions were concretely determined and technically described.

Against petitioners’ denial that Lot 3 had been partitioned, the Court treated the approved subdivision plan of Lot 3 (LRC PSD-17370) as controlling. The Court also found that Lot 3-A had been adjudicated to

Case Syllabus (G.R. No. L-44664)

The case involved a petition for review on certiorari seeking to nullify the Court of Appeals (C.A.-G.R. No. 56049-R) decision dated June 23, 1976 and its resolution dated September 15, 1976.
The Court of Appeals had affirmed the decision of the Court of First Instance of Bulacan dismissing petitioners’ complaint for reconveyance of real property.
The dispute centered on whether a Dokumento ng Bilihan evidencing the sale of Lot 3-A was valid and whether petitioners could still exercise the right of legal redemption.

Parties and Procedural Posture

Petitioners were Bernardo Mendoza I, Bernardo Mendoza II, Guadalupe M. Mangale, Juliana M. Samonte, Pacita M. Samonte, Ricardo Mendoza, Francisco Mendoza, Patricia Mendoza, Olympia M. Dizon, Romeo Mendoza, Reynaldo Mendoza, Remedios M. Bernabe, and Trinidad Manuel Mendoza.
Respondents were the Hon. Court of Appeals, Renato Samonte, and Lucia de la Cruz Samonte.
The trial court dismissed petitioners’ action on October 15, 1973.
The Court of Appeals affirmed that dismissal on June 23, 1976, and denied petitioners’ motion for reconsideration on September 15, 1976.
Petitioners elevated the matter to the Supreme Court via a petition for review on certiorari.

Key Factual Allegations

Petitioners commenced the action for reconveyance on February 18, 1969 in the Court of First Instance of Bulacan against spouses Renato Samonte and Lucia de la Cruz Samonte.
Petitioners later filed a First Amended Complaint on October 27, 1970 alleging that, even if the sale were declared valid, they would still be entitled to legal redemption.
During pre-trial on June 28, 1971, the parties submitted a partial stipulation of facts showing that petitioners were legal heirs of the late Arcadio Mendoza of Barrio Taliptip, Bulacan, Bulacan.
The stipulation stated that Arcadia Mendoza (as spelled in the record) and Trinidad Manuel Mendoza were married on April 22, 1923 in the Catholic Church, Parish of Bulacan.
The stipulation recorded that Arcadia Mendoza died on November 4, 1944 and left properties, including land covered by Original Certificate of Title No. 12192.
The stipulation identified Lot 3-A as a portion of Lot 3, with the technical description and boundaries stated in detail.
The stipulation asserted that Arcadio Mendoza acquired ownership of the parcels, including Lot 3, through donation from the late Jose Samonte, a mode of acquisition previously recognized and adjudicated in Victor Samonte, et al. v. Maria Samonte, et al., G.R. No. 22891-R.
It was stipulated that Lot 3 was subdivided into Lot 3-A and Lot 3-B by subdivision plan (LRC) Psd-17370 dated September 7, 1961 and approved by the Commissioner of Land Registration.
The stipulation stated that on June 26, 1962, Trinidad Manuel Mendoza sold Lot 3-A to spouses Renato Samonte and Lucia de la Cruz Samonte.
The stipulation described the Dokumento ng Bilihan as being written in Tagalog, signed by Trinidad Manuel Mendoza as vendor, witnessed by Juliana Mendoza and Pacita Mendoza Samonte, and notarized by Atty. Pedro Magsalin.
The stipulation reproduced the vendor’s declarations in the document indicating an agreement to partition whereby Lot 3-A would belong to Trinidad Manuel Mendoza and Lot 3-B to the children.
The document declarations also indicated that the sale was undertaken with the children’s knowledge and as an execution of the partition arrangement, and that a stated consideration had been received.
The stipulation further indicated that the improvements on Lot 3-A were placed by the defendant spouses.
After the sale, the defendants started building a house openly on the disputed lot.

Contested Validity of Deed

Petitioners argued that the Dokumento ng Bilihan was void because Lot 3-A was still allegedly under litigation as of June 26, 1962.
Petitioners emphasized that C.A.-G.R. No. 22891-R was decided only on September 23, 1964 and contended that they therefore had not executed any partition agreement, judicial or extrajudicial.
Petitioners relied on the Court of Appeals’ earlier disposition in C.A.-G.R. No. 22891-R to assert that Lot 3-A (and other lots) was donated by Jose Samonte to Arcadio Mendoza, and thus Trinidad Manuel Mendoza was entitled only to the share of a legitimate child or one legitimate child’s rights and interests, citing Article 996 of the Civil Code.
Petitioners contended that since Trinidad Manuel Mendoza could only sell her 1/13 rights and interests over Lot 3-A, the Dokumento ng Bilihan was void insofar as it affected the other petitioners’ rights and interests.
Petitioners further argued corollarily that, if the sale were invalid as to their shares, they could still exercise legal redemption under Article 1620 of the Civil Code.
Private respondents asserted that Trinidad Manuel Mendoza declared under oath in the Dokumento ng Bilihan that Lot 3-A was given to her by reason of an agreement of partition with her children.
Private respondents maintained that Trinidad Manuel Mendoza declared that the children knew of and consented to the sale, and that the consideration was known to her and her children.
Private respondents argued that the document was written in Tagalog, the dialect spoken by petitioners in Bulacan, that petitioners Pacita Samonte and Juliana Samonte signed as witnesses, and that the document was prepared and notarized by Atty. Pedro Magsalin, described as th