The Supreme Court ruled that the action for recovery of ownership and partition filed by the heirs was not barred by prescription because the co-heir’s repudiation of the co-ownership was made known to the other heirs only in 1998, and the action was filed within the prescriptive period. This case clarifies that prescription begins to run against co-heirs only from the moment of clear repudiation of co-ownership, impacting how inheritance claims are pursued and defended.

From Sibling Rivalry to Legal Battle: Unpacking Inheritance Rights and Time Limits

The case revolves around a parcel of land originally owned by Juanita Padilla. Upon her death, her heirs, including Ricardo Bahia, sought to partition the land. However, they discovered that Ricardo had declared the land solely in his name based on an Affidavit of Transfer of Real Property allegedly executed by Juanita in his favor years prior. This prompted the other heirs to file a case for recovery of ownership, possession, partition, and damages against Dominador Magdua, who had purchased the land from Ricardo’s daughters. The central legal question is whether the heirs’ action is barred by prescription, given the time elapsed since the affidavit was executed.

The Regional Trial Court (RTC) initially dismissed the case for lack of jurisdiction, then reconsidered, ultimately dismissing it based on prescription. The RTC reasoned that since the Affidavit was executed in 1966 and the case was filed only in 2001, the action to question the Affidavit had prescribed. The Supreme Court, however, found that the RTC incorrectly relied solely on the Affidavit without considering other crucial evidence presented by the petitioners. It is a well-established rule that factual findings of lower courts are generally binding, but exceptions exist, such as when the conclusion is based on speculation or a misapprehension of facts, warranting a review.

The Supreme Court emphasized that the alleged deed of sale between Ricardo’s daughters and Dominador was not presented as evidence, nor was there any proof that Ricardo authorized his daughters to sell the land. Without such evidence, the RTC’s conclusion that Ricardo might have consented to or ratified the sale was speculative. The absence of proof regarding Ricardo’s open, continuous, and exclusive possession of the land for over 30 years further weakened Dominador’s claim of extraordinary acquisitive prescription. This is important because under the Civil Code, a party claiming acquisitive prescription must demonstrate clear and convincing evidence of such possession.

Moreover, the Court addressed the critical issue of co-ownership. Ricardo and the petitioners were co-heirs or co-owners of the land, and under Article 494 of the Civil Code, prescription does not run in favor of a co-owner against other co-owners unless there is a clear repudiation of the co-ownership. Article 494 explicitly states:

Art. 494. x x x No prescription shall run in favor of a co-owner or co-heir against his co-owners or co-heirs as long as he expressly or impliedly recognizes the co-ownership.

For a co-owner’s possession to be deemed adverse, the following requisites must concur: (1) unequivocal acts of repudiation amounting to ouster of the other co-owners, (2) such acts of repudiation must be made known to the other co-owners, and (3) the evidence must be clear and convincing. The Supreme Court found that these requisites were met, but only from 5 June 1998, when Ricardo notified his co-heirs that he had adjudicated the land solely for himself. Therefore, the prescriptive period began to run from this date, not from the execution of the Affidavit in 1966. Since the action was filed in 2001, only three years had lapsed, falling short of the required 10 or 30-year acquisitive prescription period.

Dominador’s argument that prescription commenced in 1966 was deemed erroneous because it relied solely on the Affidavit without providing corroborative evidence to establish Ricardo’s possession since that year. Citing Heirs of Maningding v. Court of Appeals, the Court reiterated that evidence of possession must be clear, complete, and conclusive to establish prescription. As the land was unregistered, Dominador bought it at his own risk, and he could not claim protection without proving his legal entitlement.

Addressing the jurisdictional issue, the Supreme Court clarified that the RTC did not err in taking cognizance of the case. While the assessed value of the land was only P590.00, which would typically fall under the jurisdiction of the Municipal Trial Court (MTC), the action was not merely for recovery of ownership and possession but also for annulment of a deed of sale. Actions for annulment of contracts are considered incapable of pecuniary estimation and fall under the jurisdiction of the RTC, as held in Singson v. Isabela Sawmill:

In determining whether an action is one the subject matter of which is not capable of pecuniary estimation this Court has adopted the criterion of first ascertaining the nature of the principal action or remedy sought. If it is primarily for the recovery of a sum of money, the claim is considered capable of pecuniary estimation… However, where the basic issue is something other than the right to recover a sum of money, where the money claim is purely incidental to, or a consequence of, the principal relief sought…are cognizable by courts of first instance (now Regional Trial Courts).

The principal action here was to recover ownership and possession by questioning the Affidavit and the validity of the deed of sale. This makes the action incapable of pecuniary estimation and thus within the jurisdiction of the RTC. The Supreme Court reiterated the rule that jurisdiction is determined by the allegations in the complaint and the character of the relief sought, irrespective of whether the party is entitled to all or some of the claims.

In conclusion, the Supreme Court found that the Affidavit alone was insufficient to establish Dominador’s rightful claim of ownership and directed the RTC to try the case on its merits to determine the rightful owner of the land.

FAQs

What was the key issue in this case?	The key issue was whether the action for recovery of ownership and partition filed by the heirs was barred by prescription, considering the Affidavit of Transfer and the subsequent sale of the land.
When does prescription begin to run in cases of co-ownership?	Prescription begins to run against co-heirs only from the moment of clear repudiation of the co-ownership, and this repudiation must be made known to the other co-owners.
What evidence is required to prove acquisitive prescription?	To prove acquisitive prescription, there must be clear, complete, and conclusive evidence of open, continuous, exclusive, and notorious possession of the property for the period required by law.
What is the significance of Article 494 of the Civil Code in this case?	Article 494 states that prescription does not run in favor of a co-owner or co-heir against other co-owners or co-heirs unless there is a clear repudiation of the co-ownership, which is crucial in determining when the prescriptive period begins.
How did the Court determine jurisdiction in this case?	The Court determined jurisdiction based on the nature of the principal action, which was not merely for recovery of ownership but also for annulment of a deed of sale, making it an action incapable of pecuniary estimation and thus within the jurisdiction of the RTC.
What happens when a buyer purchases unregistered land?	When a buyer purchases unregistered land, they do so at their own risk and are not afforded protection unless they can manifestly prove their legal entitlement to the claim.
What did the Supreme Court direct the RTC to do?	The Supreme Court directed the RTC to try the case on its merits to determine who among the parties is legally entitled to the land, as the Affidavit alone was insufficient to establish ownership.
What is the effect of a tax declaration on proving ownership?	While a tax declaration does not prove ownership, it is evidence of a claim to possession of the land and can support a claim of ownership when coupled with other evidence.

This ruling underscores the importance of clear communication and documentation among co-heirs regarding property rights and intentions. The case serves as a reminder that claims to property must be supported by concrete evidence and that the defense of prescription requires a clear showing of open, continuous, and adverse possession. Parties involved in inheritance disputes should be diligent in gathering and preserving evidence to support their claims.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Heirs of Juanita Padilla vs. Dominador Magdua, G.R. No. 176858, September 15, 2010