G.R. No. 126996 February 15, 2000
HEIRS OF CESARIO VELASQUEZ, petitioners, vs. THE COURT OF APPEALS and HEIRS OF ANATALIA DE GUZMAN, respondents.

FACTS

Spouses Cornelio Aquino and Leoncia de Guzman died intestate and childless. Leoncia was survived by her sisters, Anatalia de Guzman (predecessor of the respondents) and Tranquilina de Guzman (grandmother of the petitioners). The respondents, heirs of Anatalia, filed a complaint for annulment, partition, and damages against the petitioners, heirs of Cesario Velasquez (son of Tranquilina). They alleged that before her death, Leoncia convened a conference where she stated that earlier documents donating properties to Cesario were not genuine and that Cesario promised to divide the properties equally with Anatalia’s heirs. They claimed entitlement to one-half of the six parcels of conjugal land acquired by the Aquino spouses.
The petitioners asserted that the properties had been validly conveyed during the spouses’ lifetime through specific deeds: a donation propter nuptias and deeds of conveyance to Cesario Velasquez and Camila de Guzman, and a donation inter vivos to some petitioners. They denied the alleged conference and promise, and contended their possession was peaceful and adverse. They also raised affirmative defenses including res judicata, arguing previous cases involving the same parties and properties had been dismissed.

ISSUE

Whether the respondents have a legal right to demand the partition of the subject properties.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals’ decision. The legal logic is anchored on the rules of intestate succession and the nature of the properties involved. Upon the death of the childless spouses Aquino, their conjugal estate was dissolved. The net conjugal properties became subject to partition: one-half belonged to the surviving spouse, Cornelio, as his share, and the other half constituted the estate of the deceased spouse, Leoncia, to be inherited by her legal heirs. Since Cornelio subsequently died, his own estate, comprising his share from the conjugal partnership and any other separate property, also passed to his legal heirs.
Crucially, the respondents, as heirs of Anatalia (Leoncia’s full-blood sister), and the petitioners, as heirs of Tranquilina (Leoncia’s other full-blood sister), are all legal heirs of Leoncia. They inherit in equal degree. Therefore, they are co-owners of Leoncia’s half of the net conjugal estate. The petitioners’ claim of exclusive ownership based on various deeds was correctly rejected by the lower courts. The respondents, as co-owners, possess the imprescriptible right to demand partition of the commonly owned property at any time. The defense of res judicata was also properly dismissed, as the elements thereof were not sufficiently established. Consequently, the action for partition was rightly upheld.