G.R. No. L-8780; November 6, 1914

FACTS:
The plaintiffs, children and grandchildren of the spouses Dimas de Guzman and Felipa de los Reyes, filed an action to recover possession and be declared owners of a parcel of land, with damages for its wrongful withholding. The defendants filed a demurrer, which was overruled by the lower court. In their answer, the defendants claimed they acquired the land by purchase from one of the plaintiffs, Petra de Guzman, for P2,000. The lower court found that the land was inherited by Petra de Guzman and the other plaintiffs from their parents and that no formal partition had been made among the co-heirs. It held that Petra de Guzman sold only her undivided interest, making the defendants owners of a one-fifth share, and ordered the defendants to return possession to the plaintiffs as co-owners and pay P800 in damages, with a partition to follow.

On appeal, the Supreme Court found from the evidence that prior to their death, the parents had made a partition of all their real estate among their children, giving the specific parcel in question to Petra de Guzman as her share. After her parents’ death, Petra de Guzman sold the land to the defendants, who took possession as owners. This partition, though not reduced to writing, was mutually assented to by all heirs and was valid.

ISSUE:
Whether Petra de Guzman had valid title to the parcel of land, enabling her to validly convey full ownership to the defendants.

RULING:
The Supreme Court REVERSED the lower court’s decision. It ruled that the oral partition among the heirs of Dimas de Guzman and Felipa de los Reyes was valid and effective. At the time of the partition, the parcel in question was allotted to Petra de Guzman as her exclusive share. Consequently, she became the sole owner of that parcel and had the perfect right to sell and transfer full ownership to the defendants. The other plaintiffs had no right, title, or interest in the land as owners or in its possession. The defendants, therefore, acquired valid title and were not liable under the complaint. No costs were awarded.