G.R. No. 255538 , January 25, 2023
Elena Gaerlan-Ostonal, Petitioner, vs. Romeo Flores, Randy Flores, Heirs of Florencio Gaerlan, The Office of the Municipal Assessor of Bauang, La Union, and The Office of the Provincial Assessor of La Union, Defendants, Heirs of Efren Delim, Respondents.

FACTS

Petitioner Elena Gaerlan-Ostonal filed a Complaint for Cancellation of Tax Declaration, Declaration of Nullity of Extra-Judicial Settlement of Estate, Quieting of Title, Temporary Restraining Order and Injunction, and Damages. She claimed to be a legitimate child and heir of the late Chan Jut Co (also known as Emiliano Gaerlan/Emiliano Chan) and Gorgonia Gapuz, who were allegedly married on January 1, 1913. She asserted that the subject 727-square meter parcel of land in Bauang, La Union, was gifted to Gorgonia on their wedding day and was declared for tax purposes in Chan Jut Co’s name. Elena alleged that without her knowledge and consent, Felicidad Gaerlan, Efren Delim, and Romeo Flores, claiming to be compulsory heirs of Chan Jut Co, executed an Extra-Judicial Settlement with Waiver dated March 29, 1983, adjudicating the subject property among themselves, leading to the cancellation of the original tax declaration and its transfer to new ones in their names. In defense, the Heirs of Efren Delim contended that the legitimate wife of Emiliano was Esperanza Flores, not Gorgonia Gapuz, and that the subject land was part of Emiliano and Esperanza’s conjugal property. They asserted ownership through a series of tax declarations and possession for almost 28 years. The Regional Trial Court (RTC) ruled in favor of Elena, declaring the Extra-Judicial Settlement void and ordering the cancellation of the subsequent tax declarations. On appeal, the Court of Appeals (CA) reversed the RTC, dismissing Elena’s complaint for lack of merit, finding that she failed to prove the existence of the marriage between Chan Jut Co and Gorgonia Gapuz.

ISSUE

Whether the Court of Appeals correctly reversed the Regional Trial Court ruling and dismissed Elena Gaerlan-Ostonal’s complaint for lack of merit.

RULING

No. The Supreme Court granted the petition, reversing the Court of Appeals’ Decision and Resolution. The Court held that the CA erred in dismissing the complaint. It clarified that while the action involved a declaration of heirship, such a declaration is permissible in an ordinary civil action when necessary to resolve the cause of action, such as for the nullification of deeds divesting property from the estate. On the merits, the Court found that Elena sufficiently proved the marriage of her parents, Chan Jut Co and Gorgonia Gapuz, through competent evidence, including a Joint Affidavit from the wedding sponsors, certifications from the parish priest and local civil registrar, and certificates of birth and death. The Court noted that the Heirs of Efren Delim judicially admitted in their Answer that Chan Jut Co and Gorgonia Gapuz were married, which bound them and rendered the issue of the marriage’s existence settled. Consequently, the Extra-Judicial Settlement was declared void for excluding Elena, a legitimate heir, and the subsequent tax declarations issued pursuant to it were ordered cancelled. The RTC Decision was reinstated with modification, deleting the awards for moral damages and attorney’s fees.