Case Summary (G.R. No. 160956)
Relevant Properties
The properties in dispute consist of the following parcels:
- Parcel I: Residential land, 684 square meters.
- Parcel II: Coconut land, 4.3731 hectares.
- Parcel III: Residential land, 1,395 square meters.
- Parcel IV: Abaca and coconut land, 42.6127 hectares.
Background of Dispute
In 1966, an oral partition was conducted regarding parcels III and IV, allocating half to Joaquin and the other half to the respondents. However, this partition was not documented due to Joaquin's refusal to execute a deed. Tensions arose in 1989 when the respondents sought to occupy their respective shares, which Joaquin obstructed. Consequently, the respondents filed for judicial partition and recovery of possession in the Regional Trial Court (RTC) of Camarines Sur.
Claims by Joaquin Quimpo
Joaquin denied the material allegations and claimed absolute ownership of parcels III and IV, alleging that he had purchased these properties from Eustaquia in 1946. Joaquin provided deeds of sale to support his claim, asserting continuous possession since that time. However, the respondents argued against his ownership, prompting further legal action.
RTC Decision
On December 12, 1996, the RTC ruled in favor of the respondents, declaring them co-owners of the properties and invalidating Joaquin's claims. The court found that the deeds of sale lacked consideration and consent, as Eustaquia was 91 years old and not gainfully employed at the time of execution. The RTC upheld the oral partition established in 1966, leading to the directive for both parties to formalize the partition of the properties.
Court of Appeals Ruling
The Court of Appeals affirmed the RTC decision on July 22, 2003, further substantiating that Eustaquia's consent to the sale was likely compromised due to her advanced age and health conditions. The appellate court dismissed Joaquin's claims of prescription and laches, stating that no repudiation of co-ownership had occurred on the part of the respondents.
Petition for Review on Certiorari
The Quimpos submitted a petition for review, claiming several errors in the CA's ruling, including the denial of their ownership through the deeds of sale and insufficient evidence of the respondents' claims to co-ownership. They underscored the validity of the deeds of sale and the alleged inadequacy of evidence submitted by the respondents.
Supreme Court's Analysis
The Supreme Court, in its review, affirmed the factual findings and conclusions of both the RTC and CA, reiterating the principle that the validity of deeds based on lack of consideration renders it void ab initio. The Court distinguished that mere tax declarations do not establish ownership, especially since the relevant declarations were still under Eustaquia’s name. The evidence for Joaquin's claimed ownership, including his employment status at the time of the sale, was insufficient to override the presumption created by respondent's length of possession.
Co-Ownership and Partition
The Court reinforced the notion that any co-owner has the right to demand partition at any time, underscoring that the action for partition
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Case Background
- The case originates from a Petition for Review on Certiorari filed to contest a decision made by the Court of Appeals on July 22, 2003, and its subsequent resolution on October 16, 2003.
- Eustaquia Perfecto-Abad owned several parcels of land in Goa, Camarines Sur, which included residential and agricultural properties.
- Upon her intestate death in 1948, Eustaquia left behind her properties to her grandchild, Joaquin Quimpo, and great-grandchildren, the Abad siblings: Consuelo, Ireneo, Danilo, Marites, Anita, and Helen.
- An oral partition of certain properties occurred in 1966, dividing the estate between Joaquin and the Abad siblings, though no formal document was executed.
Issues and Contentions
- Joaquin Quimpo later denied the allegations made by the Abad siblings and claimed absolute ownership of two parcels (III and IV) based on alleged deeds of sale from Eustaquia dated 1946.
- The Abad siblings filed for judicial partition and recovery of possession after being denied access to their allotted shares by Joaquin.
- The trial court declared the deeds of sale void due to lack of consideration and consent, asserting that Eustaquia was 91 years old and incapable of giving valid consent at the time of the sale.
Trial Court Decision
- The Regional Trial Court ruled in favor of the Abad siblings, recognizing them as co-owners of