G.R. No. 200544 , August 17, 2022
Ilocos Norte Electric Cooperative, Petitioner, vs. Cynthia Gertrudes Andres-Ranjo, Elma Andres Marañon, represented by her husband, William G. Marañon, Respondents.

FACTS

This case originated from a complaint for ownership filed by Delfino Andres against Concepcion Segundo and Ilocos Norte Electric Cooperative (INEC). Delfino claimed ownership of a 10,000-square-meter portion of Lot No. 23315, which he allegedly purchased in 1957 from Felipa Segundo Ruiz, a co-owner. He sought to restrain INEC from developing the land. INEC claimed it purchased an 8,000-square-meter portion of the same lot from Concepcion Segundo in good faith in 1991. A geodetic engineer’s survey revealed both parties’ property descriptions were defective and concluded they were claiming the same parcel of land.
Delfino died during the pendency of the case. His son, Neil Benjamin Andres, claiming to be the sole heir, entered into a compromise agreement with INEC, which the Regional Trial Court (RTC) approved in 1999. Subsequently, respondents Cynthia Andres-Ranjo and Elma Andres-Marañon, Delfino’s legally adopted daughters, filed a petition to annul the RTC order, arguing the compromise deprived them of their hereditary share. The Court of Appeals granted the petition, annulled the compromise agreement, and remanded the case for trial. Upon remand, the RTC ruled in favor of the respondents, declaring them owners of a two-thirds portion of the subject property. The CA affirmed this decision.

ISSUE

The core issue is whether the respondents, as compulsory heirs, have a legal right to intervene and claim ownership over the disputed property, thereby rendering the compromise agreement between Neil Andres and INEC invalid as to their shares.

RULING

The Supreme Court denied INEC’s petition and affirmed the CA’s decision. The Court held that the respondents, as legally adopted children of the original plaintiff Delfino Andres, are his compulsory heirs. Upon Delfino’s death, his rights to the property in litigation were transmitted by operation of law to his heirs, including the respondents. Consequently, Neil Andres could not solely represent the entire estate or validly compromise the claim over the property without the participation and consent of his co-heirs, the respondents.
The compromise agreement was void as to the respondents’ shares. A compromise requires the consent of all parties whose rights are prejudiced. Since the agreement purported to settle the ownership claim over property that had become part of Delfino’s estate, it required the consent of all his compulsory heirs. Neil’s unilateral act bound only his own prospective share, not the shares of his sisters. Therefore, the respondents properly intervened to assert their successional rights. The trial court correctly proceeded to adjudicate the merits of the ownership claim, ultimately finding for the respondents based on the evidence presented, which established their predecessor’s claim over the property.