Quimpo v. Beltran
REITERATIONFacts
The Antecedents: Eustaquia Perfecto-Abad owned several parcels of land. Upon her death intestate in 1948, these lands were inherited by her grandchild, Joaquin Quimpo, and great-grandchildren, the respondents. In 1966, Joaquin and the respondents allegedly undertook an oral partition of Parcel III (San Jose property) and Parcel IV, with each half allocated to Joaquin and the respondents. No document of partition was executed as Joaquin refused. Consuelo and Ireneo occupied their shares of the San Jose property and installed tenants on their share of Parcel IV. Joaquin became the administrator of the undivided properties and the shares of his minor co-heirs (Danilo, Marites, Anita, and Helen). In 1989, Joaquin prevented Danilo, Marites, Anita, and Helen from occupying their allotted portions and refused to partition Parcels I and II, prompting the respondents to file a complaint for judicial partition, recovery of possession, accounting, and damages. Procedural History: Joaquin denied the allegations, claiming absolute ownership over Parcels III and IV by virtue of deeds of sale allegedly executed by Eustaquia in 1946, and asserting continuous, peaceful, and adverse possession since then. He also claimed prescription and lack of cause of action. During the pendency of the case, Joaquin died and was substituted by his heirs (the Quimpos). The Regional Trial Court (RTC) ruled in favor of the respondents, declaring them co-owners of all properties, voiding the deeds of sale for lack of consideration and consent, and upholding the oral partition. The RTC ordered the parties to execute a written agreement of partition and ordered the substituted defendants to deliver six hectares of Parcel IV to Danilo, Marites, Anita, and Helen. The Court of Appeals (CA) affirmed the RTC ruling, finding it plausible that Eustaquia's consent was vitiated due to her age and sickness, and that the deeds surfaced late. The CA also rejected the argument of prescription and laches, stating that prescription does not run against heirs who have not repudiated co-ownership. The Petition: The Quimpos filed a petition for review on certiorari, assailing the CA's ruling that they did not acquire ownership via the deeds of sale, that co-ownership exists, that respondents proved filiation, that laches barred respondents' action, and that respondents were entitled to attorney's fees. They insisted on the validity of the deeds of sale and the probative value of tax declarations.
Issue(s)
Whether the deeds of sale executed by Eustaquia Perfecto-Abad in favor of Joaquin Quimpo are valid. Whether co-ownership exists among the parties over the subject parcels of land, and whether an oral partition occurred. Whether the respondents sufficiently proved their filiation to Eustaquia Perfecto-Abad. Whether the respondents' action is barred by prescription and laches. Whether the respondents are entitled to attorney's fees.
Ruling
The petition is denied. The Decision and Resolution of the Court of Appeals are affirmed.
Ratio Decidendi
On the validity of the deeds of sale: The Supreme Court affirmed the findings of the RTC and CA that the deeds of sale were void ab initio. The stated considerations of P5,000.00 and P6,000.00 were found to be false, as Joaquin Quimpo was not gainfully employed in 1946 and was financially supported by Eustaquia. The Court reiterated the principle that a deed of sale with a false consideration is a false contract and is void. Furthermore, Eustaquia was 91 years old, weak, and senile at the time of the alleged execution, rendering her mentally incapacitated to give consent. The deeds surfacing 43 years later also cast doubt on their validity. The tax declarations presented by the petitioners were in the name of Eustaquia, thus weakening, not strengthening, their claim of absolute dominion since 1946. On the existence of co-ownership and the oral partition: The Court affirmed the existence of co-ownership among the parties, as they were heirs of Eustaquia. The oral partition of Parcels III and IV in 1966 was also sustained based on the principle that partition may be inferred from circumstances sufficiently strong to support a presumption, such as long possession in severalty and acquiescence. The fact that Consuelo and Ireneo occupied their portions for 43 years without disturbance from Joaquin, and that tenants were installed on Parcel IV without objection, pointed to an actual partition. The Court cited jurisprudence holding that equity will enforce oral partitions when consummated by taking possession in severalty and exercising acts of ownership, even if within the Statute of Frauds, on grounds of estoppel or part performance. On the proof of filiation: The Court found that the respondents sufficiently proved their filiation to Eustaquia. This was established by the admission of Joaquin Quimpo himself during the pre-trial, detailing the lineage from Eustaquia and Diego Abad down to the respondents, confirming their status as grandchild and great-grandchildren. On prescription and laches: The Court reiterated that an action for partition among co-owners does not prescribe and is not subject to laches, unless a co-owner has expressly or impliedly repudiated the co-ownership. The Court found no repudiation on Joaquin's part, as his actions, particularly his acquiescence to the possession of Consuelo and Ireneo, indicated recognition of co-ownership and the oral partition. Therefore, the respondents' action was not barred by prescription or laches. On attorney's fees: The Court affirmed the award of attorney's fees, finding that the respondents were compelled to litigate and incur expenses to protect their interests due to the unjustified actions of the petitioners' predecessor.
Main Doctrine
A deed of sale with a false or fictitious consideration is void ab initio. Furthermore, an oral partition, if completely or partly performed by taking possession in severalty and exercising acts of ownership, may be recognized and enforced in equity, particularly on the ground of estoppel or part performance, even if it falls under the Statute of Frauds. An action for partition among co-owners does not prescribe and is not subject to laches unless there is an express or implied repudiation of the co-ownership.