Crucillo v. Intermediate Appellate Court
REITERATIONFacts
The Antecedents: Balbino A. Crucillo died intestate in 1909, leaving two parcels of unregistered land. His heirs became co-owners and possessed portions of the land. Respondent Rafael A. Crucillo, one of the surviving children, sold a portion of the land to respondents Spouses Noceda on March 28, 1969, for P20,000.00, receiving P4,000.00 as partial payment. Petitioners protested the sale, returning the partial payment. On February 19, 1971, Rafael A. Crucillo sold another portion of the land to the Spouses Noceda for P25,000.00. Subsequently, Tax Declaration No. 376, in the name of Balbino A. Crucillo, was cancelled, and new tax declarations were issued, including one in the name of the Spouses Noceda for the land they purchased. The Spouses Noceda took possession and introduced improvements. Procedural History: Petitioners filed a complaint for annulment of the partition, sale, and tax declarations, which was dismissed for failure to exert earnest efforts towards compromise. A similar complaint was filed and amended, but some petitioners were declared non-suited. The trial court declared the Deed of Partition null and void, declared the Spouses Noceda as lawful owners of the ancestral house and lot (249.75 sq.m.), declared the new tax declarations null and void, and ordered the issuance of new tax declarations for various heirs and the Spouses Noceda, all in accordance with a sketch plan. The trial court also gave the plaintiffs 30 days to exercise their right of legal redemption over the lot sold to the Nocedas. Motions for reconsideration were denied. The Intermediate Appellate Court (IAC) modified the trial court's decision, declaring the Deed of Sale null and void and ordering the Nocedas to vacate the premises and surrender possession to the appellants, with their improvements forfeited. The IAC also ordered the appellants to pay the Nocedas damages and attorney's fees. However, upon reconsideration, the IAC set aside its earlier decision and reinstated the trial court's decision, upholding the validity of the Deed of Sale and the ownership of the Spouses Noceda, and denying the right of legal redemption. The Petition: Petitioners seek a reversal of the IAC's Resolution dated October 7, 1983, which sustained the trial court's decision declaring the Deed of Sale valid and the Spouses Noceda as lawful owners, and denying the right of legal redemption. They argue that the IAC erred in setting aside its own decision and reconsidering it to sustain the trial court's findings of a prior oral partition and a valid sale.
Issue(s)
Whether the respondent Intermediate Appellate Court erred in setting aside its own decision and reconsidering it to sustain the trial court's findings of a prior oral partition and a valid sale. Whether an oral partition of the estate of Balbino A. Crucillo among his heirs has been sufficiently established. Whether the Deed of Sale executed by Rafael A. Crucillo in favor of the Spouses Felix Noceda and Benita Gatpandan-Noceda is valid. Whether the Spouses Felix Noceda and Benita Gatpandan-Noceda acquired true and lawful ownership of the lot and the ancestral house thereon. Whether the petitioners have a right of legal redemption over the property sold.
Ruling
The Supreme Court affirmed the Resolution of the Intermediate Appellate Court dated October 7, 1983. The Court held that an oral partition among the heirs of Balbino A. Crucillo was sufficiently established by their acts of possessing respective shares, constructing improvements, and declaring them for taxation. Consequently, Rafael A. Crucillo could validly sell his share to the Spouses Noceda, who became the lawful owners thereof, including the ancestral house. The petitioners were found to have no right of legal redemption as they were no longer co-owners at the time of the sale.
Ratio Decidendi
On the issue of whether the respondent Intermediate Appellate Court erred in setting aside its own decision and reconsidering it to sustain the trial court's findings of a prior oral partition and a valid sale: The Court ruled that the petition raises questions of fact, which are generally not proper in a petition for review on certiorari. However, even considering the exceptions, the appellate court correctly appreciated the facts and its questioned resolution has sufficient evidentiary support. The Court found that the assailed Resolution of the respondent court had sufficient evidentiary support, on the basis of which the respondent court abandoned its earlier Decision. On the issue of whether an oral partition of the estate of Balbino A. Crucillo among his heirs has been sufficiently established: The Court ruled in the affirmative. The evidence showed that upon the death of Juana Aure, the heirs partitioned the estate among themselves, evidenced by their possession of respective shares, construction of improvements thereon, and declaration for taxation purposes. These acts demonstrated a firm belief that the property was theirs and indicated an agreement to divide the estate. The Court noted that it is foolhardy to claim no oral partition was made when their acts showed otherwise, and their possession, coupled with improvements and length of existence, was not by mere tolerance. The petitioners were estopped from denying the existence of an oral partition due to their acts of ownership. On the issue of whether the Deed of Sale executed by Rafael A. Crucillo in favor of the Spouses Felix Noceda and Benita Gatpandan-Noceda is valid: The Court ruled in the affirmative. Given the established existence of the oral partition, it was concluded that Rafael A. Crucillo could validly convey his share of the estate to the Spouses Noceda. The sale was considered valid and binding. On the issue of whether the Spouses Felix Noceda and Benita Gatpandan-Noceda acquired true and lawful ownership of the lot and the ancestral house thereon: The Court ruled in the affirmative. As Rafael A. Crucillo validly conveyed his share, the Spouses Noceda became the true and lawful owners of the property, including the ancestral house erected thereon. Their ownership was recognized based on the valid sale and the established oral partition. On the issue of whether the petitioners have a right of legal redemption over the property sold: The Court ruled in the negative. Since the oral partition was established and Rafael A. Crucillo validly sold his share, the petitioners were no longer co-owners of the property at the time of the sale. Therefore, they had no right of legal redemption as provided by law, as the property had become the sole property of respondent Rafael Crucillo prior to its sale to the Spouses Noceda.
Main Doctrine
An oral partition of an inherited estate among heirs, evidenced by their possession of respective shares, construction of improvements, and declaration for taxation purposes, is valid, binding, and enforceable, estopping them from denying its existence.