G.R. No. 109963 October 13, 1999
HEIRS OF JOAQUIN TEVES, et al., petitioners, vs. COURT OF APPEALS, HEIRS OF ASUNCION IT-IT, et al., respondents.

FACTS

The case involves the intestate estates of spouses Joaquin Teves and Marcelina Cimafranca. Their children executed extrajudicial settlements to adjudicate and subsequently sell their hereditary shares in two parcels of land, Lot 769-A and Lot 6409, to their sister Asuncion Teves. For Lot 769-A, deeds were executed in 1956 and 1959. For Lot 6409, a deed was executed in 1971, after which Asuncion obtained a transfer certificate of title in 1972. Upon Asuncion’s death, her heirs (the It-its) settled her estate and later sold Lot 6409 to the Baylosis spouses in 1984.
In 1984, other heirs of Joaquin Teves filed a complaint for partition and reconveyance against the heirs of Asuncion. They alleged the extrajudicial settlement documents were spurious, containing forged signatures, and that they were fraudulently deprived of their shares. They argued the deeds were null and void, thus not a valid basis for transferring ownership.

ISSUE

The primary issue is whether the extrajudicial settlements executed by the heirs are valid and binding, thereby precluding the action for partition and reconveyance.

RULING

The Supreme Court affirmed the Court of Appeals’ decision, upholding the validity of the extrajudicial settlements and dismissing the complaint. The Court ruled that the petitioners failed to substantiate their allegations of forgery with clear and convincing evidence. Mere denials and testimonies of relatives claiming familiarity with the signatures of the deceased signatories were deemed insufficient to overcome the presumption of regularity accorded to notarized documents. The deeds, being notarized, enjoy the prima facie status of public documents.
Furthermore, the Court found the action barred by laches. The petitioners unreasonably delayed in asserting their rights, filing suit only in 1984—more than 25 years after the 1956/1959 conveyances for Lot 769-A and over 10 years after Asuncion secured title for Lot 6409 in 1972. This prolonged inaction, without valid excuse, warranted a presumption that they had abandoned or declined to assert their claims. The extrajudicial settlements, coupled with the subsequent issuance of titles and long-term possession by Asuncion and her successors, vested indefeasible ownership upon them.
The Court emphasized that an extrajudicial settlement operates as a contract among the heirs. Having entered into these settlements with the requisite formalities, the petitioners are bound by their terms. Regret over the alienation of their shares does not constitute a ground for nullification. Thus, the titles derived from the settlements became incontrovertible, and the action for partition was correctly dismissed.