G.R. No. 194897, November 13, 2023
SUBSTITUTED HEIRS OF JAIME S.T. VALIENTE, REPRESENTED BY ATTORNEY-IN-FACT, CYRIL A. VALIENTE, PETITIONERS, VS. VIRGINIA A. VALIENTE, RIZAARDO A. VALIENTE, POTENCIANA A. VALIENTE, BERENICE A. VALIENTE, VISFERDO A. VALIENTE, AND CORAZON A. VALIENTE, RESPONDENTS.

FACTS

The case involves a dispute over the partition of several properties left by spouses Cerilo Valiente and Soledad Sto. Tomas Valiente. Their children were Antonio, Vicente, Elizabeth, Napoleon, and Jaime. Antonio predeceased his parents. Vicente died in 1975, survived by his wife Virginia and their children (the respondents). Elizabeth died in 1986, and Napoleon died in 2006. The respondents, as heirs of Vicente, filed a Complaint for partition and damages in 1996 against Jaime and Napoleon. They claimed that the Concepcion Pequeña property, inherited by Soledad, was fraudulently sold to Jaime and Napoleon in 1977, and that they were excluded from the partition of other properties, including the Sto. Domingo, Marupit, and Barlin properties.
Jaime and Napoleon countered that the Sto. Domingo, Marupit, and Barlin properties were allotted to them in extra-judicial partitions among the siblings in the 1960s. They asserted ownership over the Concepcion Pequeña property by virtue of a 1977 deed of sale from their mother, Soledad. They argued the action was barred by prescription and laches. The RTC ruled partly for the petitioners, declaring that ownership of the Marupit and Barlin properties had been acquired by Jaime and Napoleon through acquisitive prescription and that the claim was barred by laches. However, it found prescription had not set in for the Sto. Domingo property and that the deed of sale for the Concepcion Pequeña property was void. The CA affirmed the RTC decision.

ISSUE

The core issue is whether the respondents’ action for partition and recovery of shares in the subject properties is barred by prescription and laches.

RULING

The Supreme Court denied the petition and affirmed the CA decision. The Court meticulously applied the rules on prescription and laches to each property. For the Marupit and Barlin properties, the Court upheld the findings of the lower courts. The evidence showed that Jaime and Napoleon had taken possession under claim of ownership through extra-judicial settlements executed in the 1960s, with corresponding tax declarations issued in their names shortly thereafter. Their open, continuous, exclusive, and notorious possession for over thirty years before the 1996 complaint was filed vested ownership through extraordinary acquisitive prescription. The respondents’ prolonged inaction constituted laches.
For the Sto. Domingo property, the Court found prescription had not accrued. While an extra-judicial settlement was executed in 1966, the tax declarations were only transferred to the names of Jaime and Napoleon in 1980 and 1984. Thus, the required thirty-year period of adverse possession was not completed by 1996. Regarding the Concepcion Pequeña property, the Court found the 1977 deed of sale from Soledad to her sons void. The respondents successfully rebutted the presumption of regularity of the notarized deed by clear and convincing evidence, including testimony that Soledad was blind and could not have signed, and the deed’s questionable consideration. A void contract produces no legal effect, and the property remains part of Soledad’s estate, subject to partition. An action for partition based on co-ownership does not prescribe, but the Court noted that