Case Summary (G.R. No. 140713)
Key Dates and Applicable Law
– Intestate settlement filed December 10, 1906; terminated March 4, 1914 (Civil Case No. 217).
– Cadastral titles issued December 1, 1933.
– Complaint filed September 5, 1957; Supreme Court decision December 3, 1974.
– Applicable Constitution: 1935 Philippine Constitution.
– Governing statutes: Old Civil Code (Arts. 840, 942, trust provisions Arts. 1440–1457), Act No. 190 on prescription.
Intestate Settlement in Civil Case No. 217
Rafael O. Ramos administered the decedents’ ganancial estate, appraised at ₱74,984.93, for over six years. One-half (₱37,492.46) represented Martin’s share; one-third of that (₱12,497.48) was the free portion for natural children. A partition project was submitted April 25, 1913, signed by adult heirs and by guardian Timoteo Zayco for five minor natural children.
Project of Partition and Adjudications
Under the partition:
– Jose Ramos received land and cattle valued at ₱25,291.66.
– Agustin Ramos received land and cattle valued at ₱36,291.68.
– Granada Ramos received assets worth ₱1,891.66.
– Each natural child was to receive ₱1,785.35 in cash from the free portion (totaling ₱12,497.51).
Legitimate children agreed to pay cash awards to natural heirs and specified sums to Granada.
Judicial Approval and Closure of Proceedings
Judge Campbell approved the partition April 28, 1913, directing proof of delivery. An order of February 3, 1914 required a report. On March 2, 1914 the heirs filed a sworn manifestation acknowledging receipt of their shares, but no receipts were attached. The court then archived the record.
Cadastral Registration of Disputed Lots
Eight cadastral parcels (Nos. 1370, 1371, 1372, 1375, 2158, 2159, 2161, 2163) were later registered in equal shares to Gregoria T. Ramos (widow of Jose) and her daughter Granada under Torrens Certificates issued December 1, 1933.
Plaintiffs’ Complaint and Allegations
On September 5, 1957 five natural children (Atanacia, Emiliano, Manuel, Maria, Modesto) sued heirs of Jose Ramos—Gregoria and daughter Candida—to reconvey one-sixth shares in the eight lots under Art. 840. They alleged ignorance of Civil Case No. 217, nonreceipt of cash adjudications, and asserted a trust relationship. Defendants denied trust, invoked release, res judicata, lack of cause of action and prescription.
Lower Court Proceedings and Dismissal
The Court of First Instance dismissed the complaint on the ground of res judicata, holding Civil Case No. 217 conclusively settled Martin Ramos’s estate. Plaintiffs and defendants both appealed.
Acknowledgement and Status of Natural Children
The trial court found plaintiffs legally acknowledged natural children. Although no formal birth records existed, partition records treated them as heirs. The Supreme Court upheld that finding, noting the family’s continuous recognition and defendants’ estoppel from contesting their status.
Nature of Trusts and Imprescriptibility
Under the Old Civil Code, trusts may be express, resulting or constructive. Express trusts in immovables require writing; none was proved. The partition records negatived any trust. Even implied trusts must be clearly established. Absent clear evidence, plaintiffs could not sustain an express or resulting trust claim.
Prescription, Laches, and Bar to Relief
Subsequent cadastral leases and transfers by Jose Ramos’s heirs evidenced repudiation of any trust. Under Act No. 190 the ten-year prescription ran from 1914 (or 1917 for younger heirs). Plaintiffs’ suit, filed in 1957—more than forty years later—was barred by prescription and laches, as no timely action to challenge
...continue readingCase Syllabus (G.R. No. 140713)
Facts of the Case
- Martin Ramos and Candida Tanate died intestate on October 4, 1906 and October 26, 1888, respectively.
- They left three legitimate children (Jose, Agustin, Granada) and seven natural, acknowledged children (Atanacia, Timoteo, Modesto, Manuel, Emiliano, Maria, Federico).
- On December 10, 1906, Civil Case No. 217 was instituted in the Court of First Instance of Negros Occidental for settlement of the spouses’ intestate estate.
- Rafael O. Ramos, brother of Martin, was appointed administrator; the estate was administered for over six years.
- A project of partition dated April 25, 1913 apportioned the conjugal estate (appraised at ₱74,984.93) among heirs:
- Legitimate children received land parcels and cattle valued respectively at ₱25,291.66 (Jose), ₱1,891.66 (Granada), and ₱36,291.68 (Agustin).
- Each natural child received a cash share of ₱1,785.35 (total ₱12,497.51).
- Agreements in the partition project:
- Jose Ramos to pay certain natural children; Agustin Ramos to pay the others.
- Jose and Agustin to pay additional amounts to Granada.
- The partition was approved by Judge Richard Campbell on April 28, 1913, subject to proof of delivery of shares.
- On March 2, 1914, five heirs plus guardian Timoteo Zayco filed a sworn manifestation of receipt from the administrator.
- Eight cadastral lots of the former Hacienda Calaza and Ylaya were later registered in equal shares to Gregoria Ramos and her daughter Granada Ramos.
Procedural History
- Plaintiffs (natural children) filed Civil Case No. 4522 on September 5, 1957, seeking reconveyance of their shares in eight cadastral lots.
- They alleged breach of trust by heirs of Jose Ramos (wife Gregoria, daughter Candida Ramos, and husband Jose Bayot).
- Defendants denied trust, pleaded:
- Release by partition project and court orders (res judicata).
- Lack of cause of action.
- Prescription.
- Timoteo Ramos disclaimed interest; Emiliano Ramos died and was substituted.
- The Court of First Instance dismissed the complaint on res judicata grounds.
- Both plaintiffs and defendants appealed.
Issues Presented
- Were the plaintiffs legally acknowledged natural children of Martin Ramos?
- Did the prior settlement and partition in Civil Case No. 217 bar the 1957 action (res judicata)?
- Was any express or implied trust established to hold the eight cadastral lots for the plaintiffs?
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