G.R. No. 232579, September 8, 2020
DR. NIXON L. TREYES, PETITIONER, VS. ANTONIO L. LARLAR, REV. FR. EMILIO L. LARLAR, HEDDY L. LARLAR, ET AL., RESPONDENTS.

FACTS

Respondents, the siblings of the decedent Rosie Larlar Treyes, filed a Complaint against petitioner Dr. Nixon L. Treyes, Rosie’s surviving spouse. They alleged that petitioner, in gross bad faith, executed Affidavits of Self-Adjudication claiming to be Rosie’s sole heir, thereby obtaining titles to her properties. Respondents asserted that, as legal heirs under Article 1001 of the Civil Code, they are entitled to shares in her estate. The Complaint prayed for four reliefs: (1) annulment of the affidavits and cancellation of the resulting titles; (2) reconveyance; (3) partition; and (4) damages.
Petitioner filed a second Motion to Dismiss on grounds of lack of jurisdiction over the subject matter, improper venue, and prescription. The Regional Trial Court (RTC) denied the motion. It held that it had jurisdiction over the causes of action for annulment, reconveyance, and damages, citing jurisprudence that an action for reconveyance based on a constructive trust prescribes in ten years from title issuance. However, the RTC explicitly recognized it had no jurisdiction over the third cause of action for partition and stated that it should be dropped from the case.

ISSUE

Did the Court of Appeals err in affirming the RTC’s denial of the Motion to Dismiss, which ruled that the RTC had jurisdiction over the respondents’ action for reconveyance?

RULING

No. The CA correctly affirmed the RTC. The core legal principle is that the heirs of a decedent may commence ordinary actions for the protection of their rights in the estate without a prior judicial declaration of heirship, provided no special proceeding for the settlement of the estate is pending. Here, there was no such pending proceeding. Respondents, as alleged intestate heirs, had the legal standing to sue for reconveyance. Crucially, the action is not for reconveyance directly to them as individuals, but for reconveyance to the estate of the decedent for subsequent distribution in accordance with law. This character of the suit places it within the realm of an ordinary civil action, over which the RTC properly exercised jurisdiction. The RTC’s correct self-limitation in dropping the partition aspect, which properly belongs to a special proceeding, further demonstrates the absence of grave abuse of discretion. The ruling preserves the distinction between ordinary actions to recover property of the estate and special proceedings for its distribution, allowing heirs to pursue remedies against fraudulent acts without awaiting a formal settlement proceeding.