Case Summary (G.R. No. 187524)
Discovery of Alleged Unauthorized Sale
In March 1991, respondents learned that Benita and other co-heirs purportedly sold the resort and family home to petitioners without respondents’ consent. Benita presented a document claimed to evidence her share in the sale, but it related to a bank loan release, not a property sale.
Initiation of Judicial Partition with Annulment and Recovery
Respondents annotated adverse claims on the titles and filed an amended complaint for judicial partition, annulment of titles, and recovery of possession, alleging irregular and unauthorized conveyances to petitioners.
Proceedings in the Regional Trial Court
Petitioners denied bad faith and asserted acquisition in good faith, claiming they purchased only the resort for P650,000 and the family home via extrajudicial settlement with other heirs for P1,000,000. They offered an undated deed of sale and a notarized settlement instrument.
Grounds for Annulment of Conveyance Documents
The RTC found the extrajudicial settlement notarized by an uncommissioned notary, the deed of sale undated with blank acknowledgment, and neither document registered with the Register of Deeds. Petitioners did not present notaries, witnesses, or experts to prove authenticity.
Decision of the Regional Trial Court
The RTC nullified both conveyance documents, ordered forfeiture of improvements, required petitioners and derivatively occupied persons to vacate and return possession, and directed the issuance of titles to heirs by intestate shares.
Findings and Reasoning of the Court of Appeals
The CA affirmed, holding the resort deed invalid as unnotarized and the family home deed suspicious due to missing execution details, lack of registration, and absence of witnesses. As private papers, their due execution required proof which petitioners failed to provide.
Petition for Annulment of Judgment and Resolution
Petitioners sought annulment of the RTC judgment and writ of execution based on alleged extrinsic fraud and lack of jurisdiction. The CA dismissed the petition, finding no deprivation of fair trial or ignorance of proceedings, and reaffirmed the RTC’s jurisdiction and findings.
Supreme Court’s Jurisdictional Analysis
Under the 1987 Constitution and RA 7691, the RTC has exclusive original jurisdiction over actions affecting titles to real property and actions incapable of pecuniary estimation. The combined complaint for partition, annulment of title, and recovery of possession fell squarely within this jurisdiction.
Scope of Action: Partition vs. Settlement of Estate
The Court distinguished judicial partition from probate proceedings. Although respondents pleaded heirship and property details, Rule 74 permits heirs of a debt-free intesta
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Facts
- Pedro L. Riaoza died intestate on November 16, 1989, leaving several heirs: his children by first wife (respondents Ma. Gracia R. Plazo and Ma. Fe R. Alaras) and his second wife Benita Tenorio Riaoza and their daughter.
- The decedent owned a resort (TCT Nos. 51354 & 51355; 351 sqm each) and a family home (TCT Nos. 40807 & 40808) in Nasugbu, Batangas.
- In March 1991 respondents discovered alleged sale of those properties by co-heirs to spouses Francisco Villafria and Maria Butiong (petitioners) without respondents’ consent.
- Benita Tenorio presented a document showing P87,352.62 receipt from Banco Silangan, which in fact released a bank loan and did not evidence any sale.
- The Register of Deeds had no record of conveyance; the titles remained registered in Pedro’s and Benita’s names.
- Upon inspection, respondents found four of eight cottages demolished and the resort padlocked.
- On July 18, 1991 a notice of extra-judicial settlement of Pedro’s estate was published; respondents annotated adverse claims and filed an Amended Complaint for Judicial Partition with Annulment of Title and Recovery of Possession on September 15, 1993.
Trial Court Proceedings
- Petitioners denied knowledge of any irregular sale and asserted good faith in acquiring only the resort.
- They produced an Extra-Judicial Settlement with Renunciation, Repudiation and Waiver of Rights and Sale (notarized by an uncommissioned notary) and an undated Deed of Absolute Sale by Benita (acknowledgment date blank; “Pedro Riaoza, Husband” not signed).
- Neither document was registered nor were notaries or witnesses presented at trial.
- The trial court found multiple defects—invalid notarial acts, lack of dates and signatures, absence of registration—and nullified both documents.
- It ordered forfeiture of petitioners’ improvements, recovery of possession by respondents, declaration of heirs’ shares, and issuance of new titles pro indiviso (October 1, 2001 Judgment).
Court of Appeals Ruling
- The CA affirmed the trial court on October 31, 2006.
- Ruled the r