GR 174727; (August, 2013) (Digest)
G.R. No. 174727; August 12, 2013
ANTIPOLO INING (DECEASED), SURVIVED BY MANUEL VILLANUEVA, ET AL., PETITIONERS, vs. LEONARDO R. VEGA, SUBSTITUTED BY LOURDES VEGA, ET AL., RESPONDENTS.
FACTS
Leon Roldan died without issue, leaving a parcel of land. He was survived by his siblings Romana and Gregoria. Romana was survived by her grandson, respondent Leonardo Vega. Gregoria was survived by her children and grandchildren, the petitioners. Leonardo filed an action for partition, claiming a one-half share in the property as Romana’s heir. He alleged that petitioners refused to partition the estate.
Petitioners, particularly the heirs of Teodora Villanueva-Francisco, resisted the claim. They asserted ownership through a purported sale of the property by Leon to Lucimo Francisco, Sr. (Teodora’s husband), and argued Leonardo’s action was barred by prescription, laches, and estoppel. The Regional Trial Court dismissed the complaint, finding that Leonardo, being merely a grandson of Romana, was only related by affinity to the decedent Leon and thus had no right to inherit or demand partition.
ISSUE
Whether respondent Leonardo Vega, as a relative by affinity to the decedent Leon Roldan, has the legal right to inherit from Leon’s estate and to demand its partition.
RULING
No. The Supreme Court affirmed the Court of Appeals’ reversal of the RTC and ruled in favor of Leonardo Vega. The core legal principle is that a co-ownership arose by operation of law upon Leon’s intestate death among his legal heirs—his siblings Romana and Gregoria. Each sibling inherited a one-half undivided share. This co-ownership extended to their own heirs upon their deaths. Thus, Leonardo, as Romana’s heir, rightly stepped into her shoes and became a co-owner of an undivided one-half portion of the property.
The Court meticulously rejected petitioners’ defenses. First, the action for partition, being an action to demand a right arising from co-ownership, is imprescriptible. Prescription does not run between co-heirs so long as the co-ownership is recognized. Second, laches did not apply as there was no finding of Leonardo’s unreasonable delay prejudicial to petitioners. Third, the claim of ownership by purchase was invalidated; the alleged deed of sale presented was unauthenticated and, critically, pertained to a different parcel of land as conclusively established by the Commissioner’s Report. Consequently, Leonardo, as a co-owner, possessed a clear right to seek judicial partition, which was properly granted.