Guillen v. Santiago
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns the co-ownership and possession of a fishpond property originally owned by Tomas Santiago. After his death, the property was inherited by his children, including petitioner Leona Santiago-Guillen and the private respondents. The property was later forfeited by the government in a criminal case involving some of the private respondents and sold at public auction to Manuel Bellosillo. The petitioners claim Leona redeemed the property for herself, asserting exclusive ownership and possession since 1963. The private respondents, however, assert co-ownership and claim Leona's redemption was on behalf of all co-owners, later evidenced by a deed of extra-judicial partition and agreement of subdivision. They further allege a subsequent lease agreement by the petitioners to Ranulfo Guillen, a brother of Fredillo Guillen, was null and void as to their shares. 2. Procedural History: The private respondents initiated this case by filing a complaint for annulment of lease agreement, delivery of possession, and damages against the petitioners before the Regional Trial Court (RTC) of Iloilo City. The RTC ruled in favor of the petitioners, finding that Leona had redeemed the fishpond with her own funds and that the private respondents had lost their rights through prescription and laches. The private respondents appealed this decision to the Court of Appeals (CA). The CA reversed the RTC's decision, holding that the property remained co-owned, that Leona's redemption was for all co-owners, and that neither prescription nor laches had set in. The CA declared the lease agreement void concerning the private respondents' shares and ordered the delivery of possession, subject to reimbursement for redemption costs. The petitioners' motion for reconsideration was denied, leading to the present petition. 3. The Petition: The petitioners seek review on certiorari of the Court of Appeals' decision. They contend that the appellate court erred in supplanting the trial court's findings, arguing that Leona Santiago-Guillen acquired exclusive ownership of the fishpond through her personal redemption and that the private respondents are barred by prescription and laches due to their failure to exercise their right to redeem within a reasonable time and Leona's subsequent acts of dominion. The petitioners specifically challenge the CA's finding that Leona's redemption was for all co-owners and argue that her actions constituted a repudiation of co-ownership. They also question the validity of the deed of extra-judicial partition, asserting Leona's signature was obtained through force and intimidation.
Issue(s)
Whether petitioner Leona Santiago-Guillen acquired exclusive ownership over Lot 30 to the exclusion of the private respondents. Whether the private respondents' action has prescribed.
Ruling
The petition is denied, and the decision of the Court of Appeals is affirmed. The property in dispute remains under co-ownership, and the private respondents' action has not prescribed.
Ratio Decidendi
On the issue of exclusive ownership: The Court found the petitioners' contention that the redemption was solely for Leona Santiago-Guillen's benefit to be flawed. Manuel Bellosillo, the purchaser at the auction, executed a document acknowledging receipt of the redemption price from both Leona and the private respondents for the repurchase of all lands of the late Tomas Santiago, including the fishpond in controversy. Bellosillo's testimony further clarified that while only Leona and he went to the provincial sheriff's office to formalize the redemption due to expenses, the other co-owners had agreed to and authorized Leona to pay the redemption price on their behalf. The Court gave credence to Bellosillo's testimony, considering him a disinterested party, and found that the trial court erred in not giving it due weight. The appellate court's findings, supported by evidence, were accorded due respect and finality. On the issue of prescription: The Court held that prescription does not lie against co-owners as long as the co-ownership is expressly or impliedly recognized. Article 494 of the Civil Code explicitly states that no prescription shall run in favor of a co-owner against his co-owners while he recognizes the co-ownership. The Court found that the petitioners failed to present definite proof of repudiation of the co-ownership. On the contrary, petitioner Leona Santiago-Guillen's act of affixing her signature to the deed of extra-judicial partition and agreement of subdivision dated June 26, 1981, unequivocally affirmed her recognition of the existing co-ownership. Her claim that her signature was obtained by force and intimidation was unsubstantiated and unconvincing, as good faith and regularity are presumed in contract execution, with the burden of proof falling on the party alleging duress.
Main Doctrine
A co-owner's possession, receipt of fruits, payment of taxes, or erection of improvements do not constitute repudiation of co-ownership unless accompanied by clear, complete, and conclusive evidence of ouster or deprivation of other co-owners' rights. Furthermore, no prescription runs in favor of a co-owner against his co-owners as long as the co-ownership is expressly or impliedly recognized.