G.R. No. 217611. March 27, 2019.
ROGELIO LOGROSA, PETITIONER, VS. SPOUSES CLEOFE AND CESAR AZARES, SPOUSES ABUNDIO, JR. AND ANTONIETA TORRES, SPOUSES NELSON SALA AND ARLENE ANG, AND SPOUSES BONIFACIO, JR., AND WELHELMINA BARUIZ, RESPONDENTS.

FACTS

Petitioner Rogelio Logrosa filed a complaint for partition against the respondents, claiming they were co-owners of eight parcels of land in Tagum City. The Transfer Certificates of Title (TCTs) for the properties, issued in May 1987, explicitly named Logrosa and all respondents as co-owners. Logrosa anchored his action on Article 494 of the Civil Code, which allows any co-owner to demand partition at any time. Respondents Spouses Torres and Welhelmina Baruiz interposed no objection. However, respondents Spouses Azares opposed the partition, arguing that Logrosa was merely their former employee and cousin, that he never contributed to the acquisition or maintenance of the properties, and that his name was included in the titles only as a form of accommodation or trust.
The Regional Trial Court (RTC) dismissed the complaint for lack of merit, finding no co-ownership existed. The Court of Appeals (CA) affirmed the RTC decision, holding that Logrosa’s evidence was insufficient to prove co-ownership. The CA gave credence to the Azarises’ claim that Logrosa and the other respondents lacked the financial capacity to purchase the properties in 1987 and were merely included in the titles for convenience.

ISSUE

Whether or not a co-ownership exists among the parties, thereby entitling petitioner Logrosa to demand judicial partition of the subject properties.

RULING

Yes, a co-ownership exists, and Logrosa is entitled to partition. The Supreme Court reversed the CA and RTC decisions. The legal logic is anchored on the evidentiary weight of public documents. The Deed of Absolute Sale and the TCTs, which are notarized and registered public instruments, clearly and conclusively identify Logrosa as a co-owner. These documents enjoy the presumption of regularity and constitute prima facie evidence of the facts stated therein. To overcome this legal presumption, the party contesting the co-ownership must present clear, convincing, and persuasive evidence. The Court found that respondents Spouses Azares failed to meet this burden. Their self-serving testimony that Logrosa was a mere employee or that the titles were held in trust, unsupported by any written trust agreement or other corroborative evidence, is insufficient to rebut the conclusive evidence provided by the TCTs. The claim of lack of financial capacity is irrelevant, as the law does not prescribe a minimum financial status for one to be a co-owner. Since co-ownership was conclusively established by the titles, Logrosa, as a co-owner, possesses the absolute right under Article 494 to demand partition at any time. The case was remanded to the RTC to proceed with the partition under Rule 69 of the Rules of Court.