G.R. No. 83175 . December 4, 1989.
SPOUSES FREDILLO GUILLEN and LEONA SANTIAGO GUILLEN, and RANULFO B. GUILLEN, petitioners, vs. COURT OF APPEALS, IGMEDIO SANTIAGO, EPETACIO SANTIAGO, DIOSDADO SANTIAGO, SILVESTRE SANTIAGO, LOURDES SANTIAGO, FELISA SANTIAGO, NELITA SANTIAGO, VINA SANTIAGO, RICHARD SANTIAGO, NELFA SANTIAGO, HILARIO SANTIAGO, GLORIA SANTIAGO, and FANNY SANTIAGO, respondents.

FACTS

The private respondents, siblings of petitioner Leona Santiago-Guillen, filed a complaint for annulment of a lease agreement, delivery of possession, and damages. They alleged they were co-owners with Leona of a fishpond, originally owned by their late father, which was sold at a public auction after being posted as a bond in a criminal case involving some respondents. The property was purchased by Manuel Bellosillo. The parties later executed a Deed of Extra-judicial Partition and Agreement of Subdivision in 1981, recognizing their co-ownership. The petitioners, however, failed to deliver the respondents’ shares and had instead leased the entire fishpond to Ranulfo Guillen (Leona’s brother-in-law) in 1980 without the respondents’ consent.
The Guillen spouses claimed sole ownership, asserting that Leona alone redeemed the property from Bellosillo in 1963 using her own funds, and that they had possessed it exclusively since then, paying taxes and declaring it in their names. They argued the respondents’ rights were barred by prescription and laches, and that Leona’s signature on the 1981 partition deed was obtained through force and fraud.

ISSUE

The core issue was whether the petitioners had acquired exclusive ownership of the fishpond, thereby rendering the lease valid and the respondents’ action barred, or whether the property remained in a state of co-ownership, making the unilateral lease invalid.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals’ decision. The legal logic centered on the law of co-ownership and prescription. The Court held that the property remained under co-ownership. Leona’s act of redeeming the property in 1963 was deemed to have been done for the benefit of all co-heirs, as evidenced by Bellosillo’s testimony and a 1971 receipt acknowledging payment for the redemption of all properties of the late Tomas Santiago. Consequently, the redemption inured to the benefit of all heirs, re-establishing the co-ownership.
Crucially, the Court ruled that prescription did not run against the respondents. Under Article 494 of the Civil Code, no prescription runs in favor of one co-owner against the others so long as the co-ownership is recognized. Leona’s signature on the 1981 Deed of Extra-judicial Partition was a clear, unequivocal recognition of the co-ownership, which negated any claim of exclusive acquisition by prescription. Acts such as payment of taxes and receipt of fruits, by themselves, do not constitute the clear repudiation of co-ownership required to start the prescriptive period. Furthermore, the petitioners failed to substantiate their claim of force and intimidation regarding the partition deed, leaving the presumption of its regularity intact. Therefore, the lease executed without the consent of all co-owners was invalid as to the shares of the respondents.