Fajardo v. Cua-Malate
REITERATIONFacts
The Antecedents: Respondent Belen Cua-Malate filed an Amended Complaint for Partition and Accounting with Damages against her siblings, including petitioner Victoria T. Fajardo. Respondent Belen alleged that she and her siblings were compulsory heirs of their late mother, Ceferina Toregosa Cua, who died intestate, leaving behind various properties. Respondent Belen claimed she did not receive her lawful share from the estate and prayed for its partition, accounting, and damages. The other siblings, except for petitioner Victoria, initially responded willing to settle amicably but questioned respondent Belen's entitlement to the reliefs sought. Petitioner Victoria, however, filed an Answer stating she was in favor of the partition and accounting. Procedural History: The case was initially filed before the Regional Trial Court (RTC) of Calabanga, Camarines Sur. After pre-trial, the parties agreed to refer the case to mediation through the Philippine Mediation Center. During mediation, all parties, including petitioner Victoria, reportedly reached an agreement on the partition of the estate. The mediator issued an order for respondent Belen's counsel to draft a written compromise agreement. A meeting was scheduled for the signing of this agreement, but petitioner Victoria did not appear, with her counsel explaining it was due to financial constraints for travel. The other siblings signed the agreement, and the RTC approved it as a judgment on compromise. Petitioner Victoria appealed to the Court of Appeals (CA), arguing the compromise agreement was not binding as she did not sign it and did not consent. The CA denied her appeal, affirming the RTC's decision. Petitioner Victoria then filed a Motion for Reconsideration, which was also denied. The Petition: Petitioner Victoria T. Fajardo filed a Petition for Review on Certiorari under Rule 45 of the Rules of Court, assailing the Decision and Resolution of the Court of Appeals. The core issue presented is whether the RTC erred in rendering its Decision based on the compromise agreement. Petitioner Victoria contends that the compromise agreement is not binding on her because she did not sign it and did not consent to its terms. The petition argues that an oral partition, even if partially performed, requires the consent of all parties, and her absence during the signing of the written agreement, coupled with her alleged lack of consent, invalidates the judgment on compromise. The Supreme Court is asked to determine if the lower courts erred in upholding the validity of the oral partition and the subsequent judgment on compromise despite petitioner Victoria's non-signature on the written agreement.
Issue(s)
Whether the RTC erred in rendering its Decision dated July 1, 2010, based on the compromise agreement entered into by the parties during the mediation conferences. Whether an oral partition among heirs is valid and binding.
Ruling
The Supreme Court denied the petition and affirmed the decision of the Court of Appeals. The Court held that the RTC did not err in approving the compromise agreement and rendering judgment thereon, as the parties had already entered into a valid and binding oral partition during the mediation conferences, which was merely reduced into writing.
Ratio Decidendi
On the issue of whether the RTC erred in rendering judgment based on the compromise agreement: The Court found the petition unmeritorious. Petitioner Victoria's assertion that she did not sign the compromise agreement because she did not agree with the partition was unsubstantiated. Both the RTC and CA factually found that the parties had reached an agreement on the partition of the estate prior to the written compromise agreement. The RTC noted that petitioner Victoria was present during the last conference and agreed to the partition of properties in both the Bicol Region and the National Capital Region. Her counsel's explanation for her absence during the signing was lack of transportation money, not disagreement with the terms. The CA also factually established that a valid oral partition was entered into by the parties during the mediation conferences. The written compromise agreement was merely to reduce into writing the oral partition already validly agreed upon. On the validity and binding effect of an oral partition: The Court reiterated that an oral partition among heirs may be valid and binding. There is no law requiring partition among heirs to be in writing to be valid. Citing Vda. de Reyes v. Court of Appeals and Hernandez v. Andal, the Court explained that an oral partition is not covered by the Statute of Frauds. Even if the written document was not signed by petitioner Victoria, the oral partition already bound all siblings. The Court also noted that courts of equity have enforced oral partitions when they have been completely or partly performed, and there was no refutation from petitioner Victoria that the terms of the compromise agreement had already been partially performed.
Main Doctrine
An oral partition among heirs is valid and binding, even if not in writing, and is not covered by the Statute of Frauds. A written compromise agreement merely reduces into writing a prior oral agreement.