Case Summary (G.R. No. 150175)
Facts of Intestate Proceedings
Maximino died intestate in 1952. Donata, as administratrix, submitted an inventory (dated 2 October 1952) listing several land parcels. At Donata’s motion, and upon uncontradicted testimony that no other heirs existed, the Cebu CFI issued an order (15 January 1960) declaring her sole, absolute, and exclusive heir. That order, presumed valid and regularly issued, was recorded in the Register of Deeds and resulted in new Torrens titles in Donata’s name in June 1960.
Partition Action in RTC
In March 1987, Maximino’s collateral heirs filed Civil Case No. CEB-5794 before the RTC seeking partition, annulment of the titles issued to Donata, and recovery of possession. They alleged fraud, breach of trust, and misrepresentation in Donata’s exclusive registration. The RTC, after trial, declared respondents entitled to one-half of the properties and ordered reconveyance and accounting. Donata’s heirs appealed to the Court of Appeals, which affirmed.
Court of Appeals Ruling
On 31 August 2001, the CA held that Donata’s registration inure to the detriment of co-heirs because she procured the CFI order by fraud, breached her fiduciary duty, and failed to notify Maximino’s collateral heirs of the proceeding. It deemed the Torrens titles vulnerable to annulment and ordered partition and reconveyance.
Supreme Court’s Decision on Merits
On 10 March 2006, relying on Article 1456 of the Civil Code and Rule 131 presumptions, the Court found no clear and convincing proof of fraud or breach of trust. The CFI order, unchallenged for decades, effectively declared Donata sole heir in rem and conferred full title. The Supreme Court accorded it the presumption of validity, held that no implied trust arose absent proof of fraud, and dismissed the complaint for partition, annulment, and recovery.
Arguments Advanced in Reconsideration
Respondents contended that Donata’s fraud in obtaining the CFI order voided it, that their succession rights vested at Maximino’s death and are imprescriptible per Quion v. Claridad and Sevilla v. De Los Angeles, and that the Supreme Court sacrificed substantive rights to procedural presumptions. They also presented a certified copy of the 1960 order belatedly, urged recognition of an implied trust, and asserted the Torrens titles were void from inception.
Fraud Allegation and Presumption of Regularity
The Court reaffirmed that settlement of estates is an in rem proceeding with constructive notice via mandatory newspaper publication. The absent heirs are bound by the presumption that the CFI judge regularly performed official duties, including service of notices and ordering publication. No direct, clear evidence contradicted these presumptions. Testimony that heirs “didn’t think” they received notice was discredited as opinion, not personal knowledge. Fraud in obtaining the CFI order was unproven; hence, no implied trust under Article 1456 arose.
Prescription of Implied Trust Action
Even if an implied trust existed, actions based on implied trusts are subject to prescription. Under Article 1144(2) of the Civil Code, respondents had ten years from accrual—defined as registration of Torrens titles in Donata’s name on 27 June 1960—to bring suit. The complaint filed in 1987 came 27 years later, clearly beyond the prescriptive period. Partition among co-owners, which generally does not prescribe, did not apply because Donata never recognized co-ownership, having affirmatively declared herself sole heir.
Laches as an Independent Bar
In addition to prescription, laches barred respondents’ claim. Donata and her successor administered, managed, and collected rents from 1952 onward, visibly exercising exclusive ownership. Maxim
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Facts
- Petitioners are the heirs of Donata Ortiz‐Briones: her surviving sister (Rizalina Ortiz‐Aguila), Rizalina’s daughter (Erlinda Pilapil), and other nephews and nieces representing two deceased sisters.
- Respondents are the heirs of Maximino R. Briones: his nephews, nieces, grandnephews, and grandnieces representing his deceased siblings.
- Donata and Maximino were married but had no children. Upon Maximino’s death on May 1, 1952, Donata instituted intestate proceedings (Special Proceedings No. 928-R) before the Cebu City Court of First Instance (CFI).
- The CFI appointed Donata administratrix on July 8, 1952, accepted her inventory of properties, and by Order dated January 15, 1960 (based on an inventory dated October 2, 1952), declared her sole, absolute, and exclusive heir of Maximino’s estate.
- Donata recorded the CFI Order with the Register of Deeds on June 27, 1960, and obtained new Torrens titles in her name (TCT Nos. 21542, 21545, 58684, among others).
- Donata died on November 1, 1977; Erlinda and her husband were appointed administrators of Donata’s intestate estate. A dispute arose when Erlinda claimed exclusive ownership of the three parcels based on two deeds of donation dated September 15, 1977.
- In 1985, Silverio Briones, a nephew of Maximino, sought letters of administration over Maximino’s estate, which was initially granted then set aside after Gregorio Pilapil’s motion.
- On March 3, 1987, respondents filed Civil Case No. CEB-5794 in the RTC for partition, annulment, and recovery of possession, later amended on December 11, 1992, alleging fraud and breach of trust by Donata in registering Maximino’s properties in her name.
Procedural History
- RTC (CEB-5794) rendered decision on April 8, 1986, in favor of respondents, declaring them entitled to one‐twelfth of six parcels and ordering reconveyance and accounting.
- Court of Appeals affirmed on August 31, 2001 (CA-GR CV No. 55194).
- Supreme Court promulgated decision on March 10, 2006, reversing both lower courts and dismissing respondents’ complaint.
- Respondents filed Motion for Reconsideration on May 10, 2006; petitioners opposed on May 19; respondents replied on May 23; collaborating counse