GR 275978; (April, 2025) (Digest)
G.R. No. 275978 , April 23, 2025
DOMICIANO AND ANSELMA HEREZO, PETITIONERS, VS. ERNESTO MAQUILING, RESPONDENT.
FACTS
The case involves a dispute over ownership and possession of a 200-square meter portion (Lot No. 322-C) of Lot No. 322 in Pavia, Iloilo, originally co-owned by sisters Teopista, Gerarda, and Marciana Herezo. Respondent Ernesto Maquiling claimed ownership, having purchased the subject property from Benigno Herezo via a Deed of Sale dated November 17, 2004. Benigno had earlier acquired it from Teopista on December 28, 1991. When Ernesto attempted to occupy the lot, petitioners Spouses Domiciano and Anselma Herezo prevented him. The Spouses Herezo asserted ownership based on a notarized Declaration of Heirship with Deed of Absolute Sale dated January 19, 2000, wherein Teopista, as the sole surviving owner, sold the entire Lot No. 322 to Domiciano. They took possession, built improvements, and paid taxes but did not transfer the title. After failed barangay settlement, Ernesto filed a Complaint for Recovery of Ownership and Possession. The Regional Trial Court (RTC) ruled in favor of Ernesto, declaring him the rightful owner and possessor. The Court of Appeals (CA) affirmed the RTC decision, prompting the Spouses Herezo to elevate the case to the Supreme Court via a Petition for Review on Certiorari.
ISSUE
Whether the Court of Appeals erred in upholding the RTC’s finding that Ernesto Maquiling has a better right to the subject property over the Spouses Herezo.
RULING
The Supreme Court denied the Petition and affirmed the CA Decision and Resolution. The Court held that the sale by co-owner Teopista of her undivided interest in the subject property to Benigno was valid. A co-owner may alienate their pro-indiviso share, provided it does not exceed the share allocable to them upon partition. The subject property did not exceed Teopista’s ideal share, and the other co-owners did not object when Benigno occupied and improved the lot in 1992, implying acquiescence. Consequently, Benigno validly acquired Teopista’s rights, which were subsequently transferred to Ernesto. The Spouses Herezo’s claim, based on a later sale from Teopista, could not defeat Ernesto’s rights. The Court also noted that factual findings of the RTC, affirmed by the CA, are generally binding. Thus, Ernesto was declared the rightful owner and possessor.