G.R. No. 232579 - TREYES vs. LARLAR

Case Summary (G.R. No. 232579)

Key Dates

May 1, 2008 – Rosie’s death (intestate)
Sept. 2, 2008 & May 19, 2011 – Petitioner’s Affidavits of Self-Adjudication filed, claiming sole heirship
June 5, 2014 – Personal service of summons on petitioner in RTC Civil Case No. 1226
Aug. 18, 2016 – CA decision affirming RTC jurisdiction
June 1, 2017 – CA resolution denying reconsideration
Sept. 8, 2020 – SC En Banc decision

Applicable Law

1987 Philippine Constitution (decision post-1990)
Civil Code of the Philippines (Articles 777 and 1001)
Rules of Court, Rule 45 (petition for review on certiorari), Rule 73 (venue for settlement of estates), Rule 74 (summary/extrajudicial settlement), Rule 78 (letters of administration), Rule 90–91 (probate/escheat), Rule 132 (evidence of public documents)

Successional Rights (Civil Code)

Art. 777: Successional rights vest at the moment of decedent’s death
Art. 1001: If decedent’s brothers/sisters survive with widower, half the inheritance to widower, half to siblings

Lower Court Proceedings

Private respondents filed RTC Civil Case No. 1226 (July 12, 2013) for:
a. Annulment of petitioner’s Affidavits of Self-Adjudication
b. Cancellation of derived Torrens titles
c. Reconveyance of shares to estate
d. Partition among heirs
e. Damages & attorney’s fees
Petitioner’s first Motion to Dismiss (lack of personal jurisdiction) resolved by proper re-service.
Petitioner’s second Motion to Dismiss raised:
a. Improper venue (waived under Omnibus Motion Rule)
b. Prescription (inapplicable; Rule 74 governs special proceedings, not ordinary actions)
c. Lack of subject-matter jurisdiction (RTC denied; partition cause dropped, RTC has jurisdiction over civil actions involving title/possession of real property above valuation thresholds – Batas Pambansa Blg. 129)
RTC Resolution (July 15, 2014): Denied second Motion to Dismiss for causes (a) & (b), retained jurisdiction over causes (annulment, reconveyance, damages), dropped partition

CA Ruling (Aug. 18, 2016 & Jun. 1, 2017)

Ordinary civil actions to annul deeds/instruments and reconvey property (“actions in personam”) bind only the parties
Heirs need not secure a prior special-proceeding determination of heirship if no probate/estate settlement proceeding pending
RTC did not commit grave abuse of discretion; venue proper; no prescription; proper subject-matter jurisdiction

Supreme Court Ruling (En Banc, Sept. 8, 2020)

Petition DENIED; CA Decision and Resolution AFFIRMED.
Clarifies rule on heirship declarations:
a. General rule (pre-Ypon): heirship status must be judicially declared in special proceedings (probate/estate settlement).
b. Current rule (post-Ypon): when no estate settlement proceeding pending, heirs may institute ordinary civil action to enforce successional rights (nullity of deed/title, reconveyance, partition, damages) without prior judicial declaration of heirship.
Heirs’ successional rights vest at decedent’s death (Art. 777), and they are real parties-in-interest from that moment.
Procedural rules (Rules of Court) on venue/prescription for special proceedings (Rule 73, Rule 74) do not bar ordinary civil actions

Case Syllabus (G.R. No. 232579)

Procedural Posture

Petition for review on certiorari under Rule 45 filed by Dr. Nixon L. Treyes (petitioner Treyes)
Assailing:
• RTC Resolution (July 15, 2014) denying petitioner’s Second Motion to Dismiss but dropping cause of action for partition for lack of jurisdiction
• RTC Order (August 27, 2014) denying petitioner’s Omnibus Motion for reconsideration
• CA Decision (August 18, 2016) and Resolution (June 1, 2017) affirming the RTC
Private respondents (Rosie’s siblings) had filed a Complaint in RTC for annulment of petitioner’s Affidavits of Self-Adjudication, cancellation of TCTs, reconveyance, partition, and damages
Petition denied; CA’s assailed Decision and Resolution affirmed

Facts

May 1, 2008: Rosie Larlar Treyes (decedent) died intestate, childless, survived by husband (petitioner) and seven siblings (private respondents)
Decedent’s estate: 14 real properties owned as conjugal property with petitioner
Sep. 2, 2008 & May 19, 2011: Petitioner executed Affidavits of Self-Adjudication claiming sole heirship; registered in Marikina City and San Carlos City RDs; TCTs issued in petitioner’s name
Private respondents discovered cancellation of most TCTs and new titles in petitioner’s name; wrote petitioner requesting estate settlement but received no reply
July 12, 2013: Private respondents filed RTC Civil Case No. 1226 for annulment of affidavits, cancellation of titles, reconveyance, partition, and damages
Summons service issues; petitioner filed:
• First Motion to Dismiss (lack of jurisdiction over person) – resolved by re-service
• Second Motion to Dismiss (improper venue, prescription, lack of subject-matter jurisdiction) – denied by RTC
• Omnibus Motion to reconsider – denied by RTC

Issue

Whether the RTC gravely abused its discretion in denying petitioner’s Second Motion to Dismiss on the ground that, absent a prior special proceeding to determine heirship, it lacke