Case Summary (G.R. No. 225159)
Antecedents
Reynaldo Reyes claims ownership of a 463 square meter parcel of land, originally owned by his grandfather, Julian Reyes. After Julian and his wife Marcela died in 1944 and 1964, respectively, their nine children inherited the property. In 1975, the heirs executed an informal partition, selling half of the land to Anastacio, while other portions were occupied by some heirs and sold to the spouses Garcia in 1989. Petitioner subsequently filed a lawsuit questioning the validity of the spouses Garcia's title based on Isidoro, another heir, selling his share without consent from other heirs.
Ruling of the Regional Trial Court
The RTC dismissed the petitioner’s complaint on April 12, 2013, affirming that the jurisdiction is established through the plaintiff's claims and that the assessed value of the property doesn't affect jurisdiction. The court concluded all heirs remain co-owners of the property. It ruled that while Isidoro could sell his share, he could not dispose of the interests of others without their consent. The court highlighted the necessity for partition as the lawful remedy, dismissing claims for recovery or nullification.
Ruling of the Court of Appeals
The CA upheld the RTC's ruling on February 16, 2016, asserting the trial court maintained jurisdiction over the subject matter and acknowledging petitioner’s standing as a real party in interest. The appellate court emphasized that only Isidoro's share could be sold, but the remedy for the dispute was partition, implying a recognition of co-ownership but not allowing specific possession claims until the property is legally partitioned.
Petitioner's Arguments
Petitioner contends that partitioning the property would be impractical and render it unserviceable for family living. He asserts that Isidoro sold more than his pro-rata share, violating the interests of other heirs, thus requesting the de facto nullification of the transaction involving spouses Garcia concerning the interests of the other heirs.
Arguments of the Spouses Garcia
The spouses Garcia counter that the issues raised by the petitioner merely reiterate prior arguments presented to the CA and do not introduce new questions of law appropriate for review under Rule 45. They assert the petitioner’s claims lack merit and that the courts correctly ruled the parcel's ownership issues revolve around partition, not nullification of the sale.
Our Ruling
The Supreme Court found the petition without merit, reiterating that a co-owner may sell their share without the other co-owners' consent, but the sale does not render it absolute over the entire property. The court emphasized that Isidoro's sale affected only his share, allowing the spouses Garcia ownership of his undivided inte
...continue readingCase Syllabus (G.R. No. 225159)
Background of the Case
- The case centers on the petition challenging the February 16, 2016 Decision and June 9, 2016 Resolution of the Court of Appeals (CA) which affirmed the earlier ruling of the Regional Trial Court (RTC).
- The subject matter involves an unregistered parcel of land in Quezon St., Bagumbayan, Taguig, originally owned by Julian Reyes and his spouse Marcela Reyes, with a total area of 463 square meters.
- Upon the deaths of Julian (1944) and Marcela (1964), their nine heirs, including the petitioner and his father Vitaliano Reyes, inherited the property.
Antecedents of the Case
- In 1975, the heirs executed a document selling half of the property to heir Anastacio.
- The remaining property was divided among Vitaliano's children and sold by another heir, Isidoro, to the respondents Wilfredo and Melita Garcia through a Deed of Sale dated August 16, 1989.
- The petitioner and Fermin Reyes, as descendants of Vitaliano, became aware of the sale in 1997 when the Garcias filed an ejectment case against Fermin.
Legal Proceedings
- The petitioner filed a complaint for recovery of ownership, quieting of title, and annulment of the Deed of Sale against the Garcias, claiming that Isidoro lacked the authority to sell the property.
- The spouses Garcia countered with various defenses, including res judicata and lack of standing of the petitioner.
Ruling of the Regional Trial Court
- The RTC dismissed both the petitioner's complaint and the counterc