G.R. No. L-2790

FACTS:
Ciriaca Millan (plaintiff-appellee) filed an action against her niece Florencia Millan and two grandnephews (defendants-appellants) concerning two parcels of land. The first property, located in Trozo, Binondo, was co-owned by the parties, with Ciriaca owning a three-fourths (3/4) share and the defendants owning one-fourth (1/4). The defendants had been collecting rents from this property. The second property, located in Tondo, was originally owned by Arcadio Santiago, the uncle of both Ciriaca and the defendants’ predeceased father, Francisco Millan. Ciriaca claimed sole ownership of the Tondo property, arguing that the defendants, as children of a nephew (Francisco) who died before the uncle (Arcadio), could not inherit from Arcadio’s estate. The defendants counterclaimed, asserting a co-ownership interest in the Tondo property and seeking an accounting and partition of both properties. The Court of First Instance ruled in favor of Ciriaca, declaring her the sole owner of the Tondo property and ordering the defendants to pay her share of the rents from the Trozo property. The defendants appealed.

ISSUE:
Whether the defendants, as children of a nephew who predeceased the decedent (their granduncle Arcadio Santiago), have a right to inherit from the decedent’s estate concurrently with a surviving niece (Ciriaca Millan).

RULING:
No. The Supreme Court affirmed the lower court’s decision. Applying the laws of succession, the Court held that the children of a nephew who died before the decedent-uncle have no right to participate in the inheritance with a surviving niece of the same decedent. The defendants’ claim of co-ownership over the Tondo property based on a long-standing mutual mistake of fact and law between the parties cannot confer title. A mistaken belief, no matter how long held, cannot prevail over the clear provisions of law or create a right where none exists. Since the property was undivided, the plaintiff’s possession did not ripen into ownership by prescription against the defendants, but conversely, the defendants’ error could not vest in them any title they did not legally possess. Thus, Ciriaca Millan was declared the sole owner of the Tondo property.