G.R. No. L-30019 November 28, 1980
AGRIPINA BERNARDO, CONSTANTINO DE LEON AND RITA BERNARDO, petitioners, vs. COURT OF APPEALS, LAUREANO BERNARDO, ELENA BERNARDO, CIPRIANO BERNARDO, ELADIO DE LEON Y BERNARDO AND SANTOS BERNARDO, respondents.

FACTS

The case involves a dispute over three parcels of land originally owned by the spouses Miguel Bernardo and Lorenzo Garcia. Their six children were Ceferino, Bonifacio, Narciso, Justo, Gregoria, and Petronila. The respondents, descendants of Ceferino, Bonifacio, and Narciso, filed an action for partition and annulment of conveyance against petitioners Agripina Bernardo (daughter of Justo) and others. They claimed the properties remained undivided community property. The petitioners asserted exclusive ownership by Justo, supported by a 1897 quitclaim document where some siblings purportedly ceded their rights to him, and by tax declarations in Justo’s and later Agripina’s names since 1906.
The trial court dismissed the complaint. The Court of Appeals initially affirmed this dismissal. However, upon motion for reconsideration, a special division of five Justices reversed its own decision. It declared the properties as community property, allocating 3/5 to the heirs of Ceferino, Bonifacio, and Narciso, and 2/5 to the heirs of Gregoria and Justo. The petitioners sought certiorari, challenging the appellate court’s authority to reverse its own decision and its new factual findings.

ISSUE

The core issue is whether the Court of Appeals acted with grave abuse of discretion in granting the motion for reconsideration, reversing its original decision, and making new findings of fact that the lands were community property despite evidence of a quitclaim and long-term exclusive possession.

RULING

The Supreme Court denied the petition and affirmed the Resolution of the Court of Appeals. The Court held that the Court of Appeals acted within its inherent power to amend its processes and orders to conform to law and justice. The reversal was not capricious but was based on a meticulous re-examination of the evidence. The appellate court found the 1897 quitclaim document ineffective to convey absolute ownership. It interpreted the document as merely an agreement for Justo to manage the properties and pay the siblings’ shares from the produce, not a waiver of their proprietary rights. This interpretation was supported by the document’s terms and the lack of reason for the siblings to completely relinquish their inheritance.
Furthermore, the quitclaim did not include all co-owners, as Narciso and Petronila were not parties thereto. The Court of Appeals also found that the subsequent tax declarations and possession by Justo and his heirs did not conclusively prove exclusive ownership, as such possession could be consistent with the management role acknowledged in the quitclaim. The Supreme Court reiterated the doctrine that factual findings of the Court of Appeals are generally final and conclusive, especially when, as here, they are supported by substantial evidence. No grave abuse of discretion was found in the appellate court’s thorough re-evaluation of the case.