Title
Spouses Marcos vs. Heirs of Bangi
Case
G.R. No. 185745
Decision Date
Oct 15, 2014
Dispute over 2,138 sqm land in Pangasinan; respondents claim ownership via 1943 sale, petitioners allege forgery. SC upheld 1943 sale, voided forged 1995 deeds, affirmed oral partition validity.
A

Case Summary (G.R. No. 185745)

Facts of the Case

On June 26, 1998, the respondents filed a complaint against the petitioners with the Regional Trial Court (RTC) aimed at annulling transfer certificates of title, recovering ownership of the property, and seeking damages. They claimed their parents had validly purchased a one-third portion of a 2,138-square meter property in 1943, but the title was eventually transferred to the petitioners under what they alleged were forged documents. The petitioners denied any wrongdoing, asserting that ownership of the property stemmed from Eusebio Bangi, their ancestor.

Background of Ownership Claims

The respondents argued that their parents, Isidro and Genoveva, had taken possession of the property after their purchase and continued to do so until their deaths. The transfer of titles to Dominador Marcos and others was based on a 1995 deed executed by Eusebio, which the respondents contended was fraudulent due to the death of Eusebio in 1918. The petitioners countered that Eusebio inherited the property legitimately and argued that a donation propter nuptias allegedly made by Eusebio's parents supported their claims of ownership.

Ruling of the RTC

In its decision dated March 26, 2007, the RTC declared both the 1995 deeds as null and void. It noted the forgery of the August 10, 1995 deed, as Eusebio could not have signed it posthumously. The RTC affirmed that the original sale by Eusebio to Isidro and Genoveva in 1943 was valid and upheld the validity of their claim to the property.

Appeal and Ruling of the Court of Appeals

The petitioners appealed to the Court of Appeals (CA), which, on September 30, 2008, affirmed the RTC's decision. The CA found substantial evidence that Eusebio had gained ownership of the property through an oral partition among heirs, despite no formal record of it. The CA ruled that the absence of a written partition did not invalidate the claim, especially given the possession and assertion of ownership by Eusebio.

Issues on Appeal

The main issue for resolution was whether the CA made a reversible error in affirming the RTC's ruling regarding the validity of the 1943 sale. The petitioners maintained that the lack of formal documentation negated any claims of ownership from Eusebio at the time of the sale.

Final Ruling of the Supreme Court

The Supreme Court denied the petition, concluding that the CA did not commit any reversible error in its affirmation. The Court stated that inheritance rights had been established through oral partition, mirroring the findin

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