Case Summary (G.R. No. 187942)
Facts and Background
Upon marrying his first wife, Elena Antonio, Felipe Prudencio acquired a parcel of land measuring approximately 13.0476 hectares, covered by Original Certificate of Title No. 1343. After Elena's death, Felipe and their children became co-owners of the land. Felipe later remarried Teodora Abad and passed away intestate. Following his death, a Deed of Extra-Judicial Partition was executed by Teodora and their children, which erroneously claimed that Teodora and her children were the sole heirs, thereby excluding the heirs from Felipe’s first marriage. This partition was published, leading to the transfer of the land entirely into Teodora’s name.
Legal Proceedings
Teodora sold the land to Spouses Cepeda, who subsequently sold it to the petitioner. Respondents-Appellees, who claimed to be rightful heirs to the land, filed a complaint for partition and reconveyance, asserting that they had been fraudulently excluded from their inheritance. The Regional Trial Court (RTC) ruled in favor of the respondents, declaring the Extra-Judicial Partition null and void, and ordered the petitioner to reconvey the bulk of the property back to the respondents.
RTC and CA Ruling
The RTC concluded that Teodora and her children acted in bad faith in executing the partition, which was subsequently upheld by the Court of Appeals (CA). The CA found that the petitioner had not proven itself to be a buyer in good faith, as the title’s defects and the existence of other heirs should have been investigated further. Thus, the CA affirmed the RTC ruling with modifications regarding the areas to be reconveyed and affirmed the nullity of the subsequent sales.
Principle of Ownership and Good Faith
The court highlighted a fundamental teaching from Segura v. Segura, stating that the determination of whether the purchaser was in good faith is not relevant if the property did not belong to the seller. The legal principle that no one can transfer more rights than they possess was crucial to the ruling, meaning that Teodora could not validly sell the shares belonging to the respondents.
Extra-Judicial Partition's Legal Standing
The court ruled that the Extra-Judicial Partition was invalid because it excluded rightful heirs, as stipulated by the Civil Code, which mandates that all legitimate children inherit in equal shares. This violation renders the partition void, which cannot be validated by time or subsequent actions.
Repercussions of the Ruling
Because the Extra-Judicial Partition was deemed void, the sales to Spouses Cepeda and subsequently to the petitioner did not lawfully transfer the proportions of the land corresponding to the excluded heirs’ shares. The court ruled that the petitioner retains only Teodora’s valid share of the land, while the larger portion corresponding to the respondents must be reconveyed.
Distribution of the Property
The court outlin
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Case Overview
- The case involves a Petition for Review on Certiorari filed by the Roman Catholic Bishop of Tuguegarao against the October 21, 2008 Decision and May 11, 2009 Resolution of the Court of Appeals (CA) in CA-G.R. CV No. 77100.
- The CA affirmed with modification the ruling of the Regional Trial Court (RTC) which declared the sale of a lot covered by Transfer Certificate of Title (TCT) No. 14306 to the petitioner as null and void, ordering the reconveyance of the property to the heirs of Florentina Prudencio.
Facts of the Case
- Felipe Prudencio was married twice, first to Elena Antonio, with whom he had five children: Valentina, Eusebia, Paula, Florentina, and Avelina. With his second wife, Teodora Abad, he had two children: Felipe Prudencio, Jr. and Leonora.
- During his marriage to Elena, Felipe acquired a 130,476 sq. m. parcel of land in Baggao, Cagayan under Original Certificate of Title No. 1343.
- After Elena's death, Felipe and their children became co-owners of the property. Felipe died intestate during his second marriage.
- Teodora and her children executed a Deed of Extra-Judicial Partition, which excluded the children from the first marriage, declaring Teodora and her children as the only heirs and transferring title to Teodora.
- Teodora sold the lot to Spouses Isidro Cepeda and Salvacion Divini, who later sold it to the petitioner for P16,500.00.