Case Summary (G.R. No. 161955)
Background of Ownership and Inheritance
Juan Mollet and Silvina Del Monte were the original owners of the aforementioned real estate, which was inherited by their daughter Josefa after their deaths. Josefa, who died intestate in 1918, left behind no descendants. Following her death, the estate was subject to intestate succession, leading to a complex web of descendants and familial relationships among the heirs, primarily the Gelardo family and the Villanuevas, among others.
Execution of the Deed of Extrajudicial Settlement
On March 17, 1965, the involved parties executed a Deed of Extrajudicial Settlement with Quitclaim, which divided the properties among various heirs. Certain heirs mitigated their shares in favor of others, particularly among the Moldes and Villanuevas. This document, however, would become the focal point of dispute several decades later.
Legal Proceedings Initiated
On January 26, 1987, Manuel Villanueva and his children, along with Mariano Dullavin's family, filed a complaint in the Regional Trial Court of Makati to annul the 1965 Deed, claiming they were misled into signing it and had not been properly informed of its implications. They sought rescission of the deed, as well as monetary damages for the perceived harms caused by the alleged fraud.
Findings of the Regional Trial Court
The Regional Trial Court ruled in favor of the plaintiffs on May 16, 1994, declaring the Deed of Extrajudicial Settlement void due to the lack of informed consent from the plaintiffs, who had not fully understood the document at the time of execution. The court found that the plaintiffs were misled into waiving their inheritance rights and that the defendants had failed to file the deed with the Register of Deeds, raising doubts in its validity. Additionally, damages were awarded to the plaintiffs.
Appeal and Ruling of the Court of Appeals
The defendants appealed to the Court of Appeals, which upheld the decision of the RTC but modified the award of damages, eliminating them entirely. The appellate court concurred that the plaintiffs had been duped into signing the fraudulent deed and highlighted that the waivers extracted from the plaintiffs lacked consideration, thus rendering them ineffective. It also pointed out that the inclusion of non-heirs in the deed affected its validity based on Article 1105 of the Civil Code.
Petition to the Supreme Court
The respondents subsequently filed a petition with the Supreme Court challenging the rulings of both the RTC and CA. They contended that the plaintiffs bore the burden of proving the validity of the deed and that they had been in possession of the property for several decades, emphasizing the importance of evidence in civil cases.
Supreme Court's Decision
The Supreme Court granted the petition on the basis t
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Case Overview
- The petition for review on certiorari was filed by Celedonio Moldes, Rosita Moldes, and Carolina Cedia against Tiburcio Villanueva, Apolonio Villanueva, Manuel Villanueva, Mariano Dullavin, Ronaldo Dullavin, and Teodora Dullavin.
- The case centers around the validity of a Deed of Extrajudicial Settlement with Quitclaim concerning three parcels of land originally owned by Juan Mollet and Silvina Del Monte.
Historical Background
- Juan Mollet and Silvina Del Monte owned three parcels of land in Taguig, identified as Lot Nos. 589, 590, and 591, totaling 3,600 square meters.
- Their daughter, Josefa, died intestate in 1918, followed by Juan Mollet in 1934 and Silvina Del Monte in 1948, leaving behind their daughter Romana Mollet, who had five children.
- The heirs of Romana Mollet include the Villanueva and Dullavin families, who eventually became the plaintiffs in the case.
Events Leading to Legal Action
- On March 17, 1965, a Deed of Extrajudicial Settlement with Quitclaim was executed, partitioning the land among the heirs.
- The Villanueva siblings and the Dullavin family later contested this deed, claiming they were misled and that their consent was obtained through fraud and deceit.
- They argued that they had not freely given their consent due to their illiteracy and lack of understanding of the document they signed.
Legal Proceedings
- On January 26, 1987, the plaintiffs filed a compla