Republic v. Baltazar-Ramirez
REITERATIONFacts
The Antecedents: Respondent Rosa Baltazar-Ramirez filed a Complaint for Recovery of Hereditary Shares against petitioner Republic of the Philippines (represented by the Air Transportation Office, later Mactan-Cebu International Airport Authority). Respondent alleged that petitioner purchased several lots, including Lot Nos. 902 and 2350, from her siblings. These lots were owned by her father, Gavino Baltazar, who died intestate. Respondent, the youngest of nine children, did not participate in the Extra-Judicial Settlement of Estate and Sale executed by her siblings, and thus claimed her 1/9 share. Procedural History: The Regional Trial Court (RTC) dismissed respondent's complaint, holding that her siblings repudiated her share and that petitioner acquired ownership through prescription and laches due to 34 years of continuous possession. The Court of Appeals (CA) reversed the RTC, ruling that there was no sufficient evidence of repudiation, that petitioner became a co-owner with respondent, and that an action for partition is imprescriptible and cannot be barred by laches. The Petition: Petitioner Republic seeks to reverse the CA decision, arguing that the CA erred in declaring them co-owners of the property.
Issue(s)
Whether the Court of Appeals erred in declaring the petitioner and respondent as co-owners of the property in dispute, considering the sale of the lots to a third person and the petitioner's subsequent possession. Whether the action for partition is barred by prescription and laches, given the petitioner's open, adverse, and exclusive possession for over 30 years after purchasing the property.
Ruling
The petition is granted. The assailed Decision of the Court of Appeals is reversed. The respondent's complaint is dismissed.
Ratio Decidendi
On the issue of co-ownership and partition: The Supreme Court held that the co-ownership was dissolved upon the sale of the lots by respondent's siblings to petitioner. Juridical dissolution of co-ownership occurs when the thing is sold to third persons or when prescription in favor of a third person takes place. The sale in 1957 and the filing of the complaint in 1991, after 34 years, coupled with petitioner's open, adverse, and exclusive possession in the concept of owner, led to the acquisition of ownership by the petitioner through prescription under Article 1141 of the Civil Code. Therefore, the parties are no longer co-owners, and the CA erred in ordering further proceedings for partition. On the issue of prescription and laches: The Court found that petitioner had been in open, adverse, and exclusive possession of the lots in the concept of owner since 1957. The respondent's inaction for 34 years before filing her complaint constituted laches. Article 1141 of the Civil Code provides that real actions over immovables prescribe after 30 years. Given that petitioner purchased the lots in good faith and for value and possessed them continuously for over 30 years, it acquired ownership to the exclusion of the respondent. If there was any deprivation of her lawful share, respondent's suit should have been against her siblings who executed the sale, not against the petitioner who acquired ownership through prescription.
Main Doctrine
The sale of undivided shares in a property by some co-heirs to a third person dissolves the co-ownership. Prescription and laches may bar a claim for hereditary shares against the third-party purchaser who has been in open, adverse, and exclusive possession in the concept of owner for over 30 years.