G.R. No. L-24679 October 30, 1975
ALFREDO N. FRIAS and BELEN LUSTRE, petitioners, vs. ANASTACIA ESQUIVEL, et al., respondents.

FACTS

This case involves a residential lot in Jaen, Nueva Ecija, originally part of the estate of spouses Victoriano Esquivel and Catalina Villamanca. Their heirs included six children and five grandchildren from a predeceased son, Alvaro Esquivel, Sr. In 1951, heir Anastacia Esquivel sold the entire lot to petitioners Alfredo Frias and Belen Lustre. Other heirs challenged this sale. In a prior case (G.R. No. L-8825), the Supreme Court upheld the sale’s validity concerning the consenting adult heirs but declared it invalid as to the minor grandchildren (Alvaro Jr., Reynaldo, Ricardo, Vicente, and Orlando), as their mother, Perpetua Zaragoza, lacked legal authority to represent them in the 1946 partition that underpinned Anastacia’s exclusive claim.
Subsequently, on February 15, 1957, Perpetua Zaragoza and her children executed a deed selling their one-seventh interest to the petitioners. However, at that time, Alvaro Jr. and Reynaldo were still minors (19 and 17, respectively), and Ricardo was insane. Their mother, Perpetua, signed on their behalf despite having lost parental authority due to her second marriage. The petitioners obtained a decree of registration for the lot in 1957. The minors and the insane heir, through a guardian, later sought to reopen the decree, leading to this petition reviewing the Court of Appeals’ decision which ordered the segregation of 116.31 square meters for the benefit of Ricardo, Reynaldo, and Alvaro Jr.

ISSUE

Whether the deed of sale dated February 15, 1957, is valid and binding upon the minor heirs Alvaro Jr. and Reynaldo and the insane heir Ricardo Esquivel, thereby precluding their claim for segregation of a portion of the registered land.

RULING

The Supreme Court affirmed the Court of Appeals with modification. The 1957 deed of sale is null and void as to Ricardo Esquivel due to his insanity at the time of execution, rendering the contract void under Article 1327 of the Civil Code. As to the minors Alvaro Jr. and Reynaldo, the contract is unenforceable. Their mother, Perpetua Zaragoza, could not validly consent on their behalf because she had lost parental authority by contracting a second marriage, pursuant to Article 320 of the Civil Code, which designates parents merely as legal administrators of their children’s property. Her signature did not constitute valid legal representation.
Consequently, the petitioners’ certificate of title, acquired after the void and unenforceable contracts, did not extinguish the ownership rights of these three respondents. They remained co-owners of the property. The Court rejected the application of the statute of limitations, as an action for reconveyance based on an implied trust, arising from the registration of property in the name of another who is not entitled to it, prescribes in ten years. The action was timely filed. To settle the matter completely, the Court ordered the remand of the case to the trial court to conduct a partition of the lot among the petitioners and the three respondents (Ricardo, Reynaldo, and Alvaro Jr.) in accordance with Rule 69 of the Rules of Court, thereby providing a direct and equitable resolution within the existing proceedings.