G.R. No. L-40488 November 28, 1975
JOSEFA BENTAJA FIGUEROA, petitioner, vs. THE HONORABLE JOSE B. JIMENEZ, Presiding Judge of the Court of First Instance of Manila, Branch VI, ROMANA TENORIO BENTAJA, PAZ BENTAJA RAMILLOSA, and TERESA BENTAJA VIZCARRA, respondents.

FACTS

The case involves the partition of properties from the conjugal estate of the deceased spouses Jose Bentaja and Romana Tenorio Bentaja. Petitioner Josefa Bentaja Figueroa, along with her sisters Paz and Teresa, are compulsory heirs. The respondent Court of First Instance, in its amended decision, declared that only Lots 1 and 4 of the Sulucan Subdivision pertained to the conjugal estate. It adjudicated to each of the three sisters a 1/12 undivided portion of these lots, with the remaining 9/12 portion allocated to the estate of their mother, Romana, whose testate proceedings were pending. The court dismissed the petition for accounting and declared other properties in dispute as the exclusive property of the spouses Ceferino Ramillosa and Paz Bentaja.
Petitioner Josefa sought a review, initially denied by the Supreme Court. Upon motion for reconsideration, she argued specifically regarding Lots 1 and 4, contending that under the principle of reserve troncal (Article 811 of the old Civil Code), the three sisters should collectively receive a larger share. She prayed that each sister be declared entitled to a 1/6 portion, totaling 3/6 for all three, with only the remaining 3/6 going to their mother Romana’s estate, thereby modifying the trial court’s allocation of 1/12 each to the sisters and 9/12 to the estate.

ISSUE

Whether the Supreme Court should modify the trial court’s amended decision regarding the distribution of Lots 1 and 4 based on the conformity of all interested parties to the petitioner’s proposed allocation.

RULING

Yes, the Supreme Court modified the judgment. The legal logic is grounded not on a substantive re-examination of the reserve troncal principle initially invoked, but on the procedural mechanism of party conformity and compromise to achieve a final settlement. The Court, in its Resolution of October 13, 1975, required the other respondent sisters, Paz and Teresa, to state whether they conformed to the petitioner’s prayer for modification.
All interested parties—respondents Paz Bentaja Ramillosa and Teresa Bentaja Vizcarra, personally and with the assistance of their counsels—filed manifestations expressly conforming to the proposed modification. This unanimous agreement among the compulsory heirs over the disputed property rendered further litigation on the merits unnecessary. The Court emphasized that since all parties had expressed conformity, the lower court’s judgment could be modified as prayed for without further proceedings.
Consequently, the Supreme Court granted the motion for reconsideration to that extent. It modified the trial court’s amended decision to declare that each of the three surviving daughters is entitled to a 1/6 undivided portion of Lots 1 and 4, and the remaining 3/6 undivided portion pertains to the estate of Romana Tenorio Bentaja. The respondent court’s amended decision was ordered to stand in all other respects. The ruling illustrates the Court’s pragmatic approach in adopting a party-driven agreement to resolve the distributive shares, thereby promoting judicial economy and respecting the autonomy of the heirs in settling inheritance matters.