Heirs of Llido v. Marquez
REITERATIONFacts
The Antecedents: The original plaintiffs and defendant Zoilo Llido were children of the late Eugenio Llido and Catalina Galopo. Seven children, including Zoilo, Faustina, and Camila, allegedly made an oral partition of their parents' properties before the war. Faustina died in 1944 and Camila in 1960, both without descendants. Zoilo and his son Margarito took possession of their shares and the exclusive properties of Faustina, as declared in a 1960 CFI decision. This decision also declared Faustina's lawful heirs to be her siblings Hilario, Dionisio, Zoilo, and Camila. Procedural History: Private respondents exerted efforts to partition the properties, leading to a complaint for partition filed on December 14, 1963, docketed as Civil Case No. 1644. After amendments and trial, the CFI of Bohol, in a decision dated January 23, 1973, ordered the partition of ten parcels of land and gave the parties 30 days to submit a project of partition. Upon failure to submit, the court, in an order dated March 31, 1973, granted an additional 20 days, warning that commissioners would be appointed if they failed to comply. Private respondents filed a motion for the appointment of a commissioner on April 2, 1973. On April 27, 1973, the respondent judge appointed three commissioners to partition the properties. Petitioners opposed this, arguing the court lacked jurisdiction and modified its decision after the 30-day period had passed. Their opposition was denied on May 28, 1973. The Petition: Petitioners filed a petition for certiorari, prohibition, and mandamus, seeking to annul the April 27, 1973 order, prohibit the commissioners from acting, and command the dismissal of Civil Case No. 1644. They raised two assignments of error: (1) the judge illegally delegated judicial duties to unauthorized third persons, violating Section 3, Rule 69 of the Rules of Court; and (2) the judge ignored the valid oral partition of parcels 1-4, violating Section 2 of the same rule.
Issue(s)
Whether the respondent judge acted beyond his jurisdiction in appointing commissioners to effect partition without stating the specific portions for each party. Whether the respondent judge erred in ignoring the alleged valid oral partition made by the parties.
Ruling
The petition is without merit and is hereby DISMISSED.
Ratio Decidendi
On the issue of appointing commissioners and alleged excess of jurisdiction: The Court found the petitioners' contention untenable. The respondent judge's decision of January 31, 1973, ordered the partition of properties and gave the parties 30 days to submit a project of partition. When they failed to do so, they were granted an additional 20 days, with a warning that commissioners would be appointed. The parties again failed to submit a project of partition, and the records indicated that the petitioners were unwilling to submit to a partition. Consequently, the respondent judge issued the questioned order of April 27, 1973, appointing commissioners. The Court emphasized that petitioners should not be rewarded for disregarding the orders of the respondent judge. The Court cited Pablu vs. Salvador and Republic Commodities Corp. vs. Oca, reiterating that refusal to obey court orders is fraught with grave consequences and can cause irreparable injury to the rule of law. The Court further stated that as long as the orders stand unmodified, they must be faithfully complied with, even if susceptible to doubts on jurisdictional or national grounds. Errors in the exercise of jurisdiction are considered errors of judgment correctible by appeal; if no appeal is filed, the decision or order becomes final and binding. On the issue of ignoring the oral partition: The Court found this contention also untenable. The decision of January 31, 1973, ordered the partition of the enumerated properties, and the proportions to be followed were those referred to in the dispositive portion of the decision, which meant equal division among all entitled parties for each specific parcel. The Court did not explicitly rule on the validity of the oral partition itself but rather focused on the parties' failure to comply with the court's orders regarding the submission of a partition project and the subsequent appointment of commissioners. The Court's directive for partition was based on the court's own apportionment as provided in Section 3, Rule 69, after the parties' failure to agree and submit their own project.
Main Doctrine
A party dissatisfied with a court order may seek reconsideration or appeal to a higher tribunal, but as long as the order stands unmodified, it must be faithfully complied with, even if susceptible to doubts. Refusal to obey court orders is fraught with grave consequences and can cause irreparable injury to the rule of law.