G.R. No. 207051 , December 01, 2021
LORENZO WILLY, SUBSTITUTED BY HIS HEIRS, NAMELY: FELICIDAD D. WILLY, BETTY WILLY CADANGEN, TONY WILLY, COSME WILLY, ROSARIO WILLY-ARMAS, ERLINDA WILLY-DAPYAWON, JOHNNY WILLY, JOSE WILLY, RODOLFO WILLY, SWINIE WILLY, ISABEL WILLY, NEDA CACANANDO, AND BENITA WILLY, HEREIN REPRESENTED BY THEIR ATTORNEYS-IN-FACT, MARIA APRILA WILLY CRUZ AND BETTY WILLY CADANGEN, PETITIONERS, VS. REMEDIOS F. JULIAN, GEORGE F. JULIAN, JOAN J. AGUIRRE, EMILY J. BUSTARDE, AND WILLIAM F. JULIAN, RESPONDENTS.

FACTS

The case involves a 67,635-square meter unregistered land in Benguet owned by Modesto Willy. On March 29, 1963, Modesto executed a written agreement conveying portions of the land to three individuals, including Emilio Dongpaen, for services rendered. On November 16, 1968, a survey delineated a 15,000-square meter portion (Lots 1 and 2) for prospective buyer Ricardo Julian. Subsequently, a series of sale transactions occurred: (1) On January 27, 1969, Dongpaen sold his 10,000-square meter portion to Ricardo; (2) On June 17, 1969, Dongpaen sold an additional 5,000 square meters to Ricardo; and (3) On June 24, 1969, Modesto sold an additional 5,000 square meters to Dongpaen via a deed notarized on June 25, 1969. Ricardo allowed Modesto’s son, Lorenzo Willy, to cultivate the lots. After Modesto’s death in 1979 and upon learning of the petitioners’ (heirs of Lorenzo) attempt to sell the land, Ricardo filed a complaint for Partition of Property and Damages before the MCTC. Petitioners denied Ricardo’s ownership, arguing Modesto was illiterate and could not have signed the documents, the 1963 Agreement had unfulfilled conditions, the action had prescribed, they were not privy to the contracts, and Dongpaen’s sale to Ricardo was invalid as it preceded Modesto’s sale to Dongpaen. The MCTC ruled in favor of Ricardo, ordering segregation of the 15,000-square meter portion. The RTC reversed the MCTC, dismissing the complaint. The CA then reversed the RTC and reinstated the MCTC decision with modifications, deleting the award for attorney’s fees.

ISSUE

Whether the Court of Appeals erred in ruling that respondents have a right to demand partition of the subject property.

RULING

No, the Court of Appeals did not err. The Supreme Court denied the petition and affirmed the CA Decision. The Court held that the 1963 Agreement was a valid contract of sale, not a conditional one, and the conditions therein pertained only to the transferees’ obligations for subdivision and titling. The series of transactions validly transferred ownership of the 15,000-square meter portion to Ricardo Julian. The contracts, being notarized, are public documents with presumptive validity, and petitioners failed to present clear and convincing evidence to overcome this presumption. The action for partition, based on co-ownership, is imprescriptible. The right to demand partition exists as long as co-ownership is recognized. The defense of prescription and laches is unavailing. Furthermore, the transactions did not violate the Statute of Frauds as they were partially executed through Ricardo’s payment and possession via Lorenzo. The Court modified the CA decision by imposing legal interest on the awarded damages.