Centeno v. Centeno
REITERATIONFacts
The Antecedents: Isaac Centeno and Melchora Arroyo, husband and wife, acquired significant property during their marriage. Isaac Centeno died on October 7, 1905, leaving a will instituting their three sons (Antonio, Valentin, and Faustino) as universal heirs to one-half of his property, to be divided equally. Melchora Arroyo, his widow, was appointed administratrix. Antonio Centeno died on October 30, 1907, leaving a will acknowledging eight children (three natural and five illegitimate) and instituting his three natural children (Martina, Jose, and Telesforo) as universal heirs to his portion of his father Isaac's inheritance and his future portion from his mother Melchora. Melchora Arroyo died on December 8, 1909, leaving a will naming Valentin Centeno as one of her heirs. Procedural History: While testamentary proceedings for Isaac and Melchora were ongoing, the heirs submitted an agreement of partition executed in October 1910 for approval by the Court of First Instance of Ilocos Sur. The court ordered publication of notice for interested parties. On April 20, 1911, the court approved the partition agreement and declared the testamentary proceedings closed, notwithstanding an opposition. Later, on October 22, 1913, the court ordered the administratrix to present an account and appointed a guardian for minor heirs. Plaintiffs and intervenors filed a complaint praying for the partition of properties described in the sixth paragraph of the original complaint, along with the portion adjudicated to defendants, and to declare the partition void concerning the portion adjudicated to defendants. Defendants filed an answer and cross-complaint, praying for the partition of certain properties and delivery of others. The trial court upheld the agreement of partition, denied the partition prayed for by plaintiffs and intervenors, and made specific pronouncements regarding various parcels of land and claims. The Petition: Plaintiffs and intervenors appealed the judgment of the Court of First Instance, assigning numerous alleged errors. They sought to have the partition declared void in part and to have a new partition made. Defendants sought to uphold the partition and have certain properties partitioned and delivered.
Issue(s)
Whether the trial court erred in not declaring the defendants in default for failing to answer the second amended complaint within the reglementary period. Whether the defendants, as acknowledged natural children of Antonio Centeno, are entitled to inherit from Isaac Centeno. Whether the defendants are entitled to the reservation of one-half of the hereditary portion inherited by Melchora Arroyo from her son Antonio Centeno. Whether the defendants are entitled to represent their natural father, Antonio Centeno, in the inheritance of their natural grandmother, Melchora Arroyo. Whether the partition made among the plaintiffs, intervenors, and defendants, and approved by the court, is valid. Whether the defendants acquired ownership of certain parcels of land by prescription. Whether the defendants are entitled to recover property, cattle, and credits adjudicated to them in the partition but still in the possession of the plaintiffs. Whether the defendants are entitled to participate in the conjugal property left by Isaac Centeno and Melchora Arroyo that was included in the inventory but not in the partition. Whether the partition of the conjugal property still remaining pro indiviso can be ordered in these proceedings.
Ruling
The Supreme Court affirmed the judgment of the lower court in all respects, with the sole modification of ordering the partition of the conjugal property left by the deceased spouses Isaac Centeno and Melchora Arroyo, which was declared pro indiviso by the lower court. The Court held that the partition agreement, once judicially approved, became final and irrevocable. The defendants, as acknowledged natural children, were entitled to their father's hereditary portion but not to represent him in his grandmother's inheritance or claim reservation of property inherited by their grandmother from their father. The Court also affirmed that the defendants could acquire ownership by prescription and were entitled to recover property in possession of the plaintiffs. The Court clarified the extent of the defendants' participation in the pro indiviso conjugal property.
Ratio Decidendi
On the procedural issue of default: The Court held that the trial court did not err in admitting the defendants' answer on the day of the trial. The motion for admission was made in open court in the presence of all parties, which obviated the need for a written motion and prior notice, as per Section 110 of the Code of Civil Procedure. Proceedings in courts of record are reduced to writing by the stenographer, allowing the adverse party to be informed and object. On the inheritance rights of natural children from their natural grandfather: The Court ruled that the defendants, as acknowledged natural children of Antonio Centeno, did not inherit directly from Isaac Centeno (their natural grandfather) by intestate succession. Instead, they inherited from their natural father, Antonio Centeno, who acknowledged them in his will and instituted them as heirs to the property he inherited from Isaac Centeno. The fact that Isaac Centeno's inheritance remained pro indiviso at the time of Antonio's death did not prevent Antonio from acquiring a right to inherit. On the reservation of property inherited by Melchora Arroyo: The Court held that the defendants, as acknowledged natural children of Antonio Centeno, were not entitled to the reservation of one-half of the property Melchora Arroyo inherited from her son Antonio. This was based on Article 811 of the Civil Code, which provides that reservable rights do not apply to illegitimate relatives. The property was acquired gratuitously by Melchora from her legitimate son, who in turn acquired it gratuitously from his legitimate father. On the right of representation in the inheritance of Melchora Arroyo: The Court ruled that the defendants could not represent their natural father, Antonio Centeno, in the inheritance of their natural grandmother, Melchora Arroyo. While Antonio Centeno was named as an heir in Melchora's will, he died before her. The law does not grant natural children the right to represent their natural father in the inheritance of their natural grandfather. This is because grandchildren inherit by representation, and such representation is only admitted for those in the same legal status as the person represented. On the validity of the partition: The Court found the partition valid and irrevocable. The extrajudicial agreement of partition, upon submission to and approval by the court after proper publication and hearing, became a judicial partition. The order of approval became final and absolute, binding on all parties. The minority of Jesus Centeno Second did not render the partition void as he was represented by his mother, whose representation was implicitly approved by the court. The status of the defendants as acknowledged natural children did not invalidate the partition, as they were acknowledged heirs and participated with full knowledge of their status. On acquisition by prescription: The Court acknowledged that if the defendants possessed certain parcels of land adversely, continuously, publicly, and as owners for ten years, they would acquire ownership by prescription, pursuant to Section 41 of Act No. 190. The judgment affirmed their exclusive ownership of parcels Nos. 113 and 114 based on this principle. On recovery of property and credits: The Court affirmed that the defendants were entitled to recover from the plaintiffs the personal and real property, cattle, and credits that were adjudicated to them in the partition but remained in the possession of the plaintiffs. This was a consequence of the validity of the partition. On participation in undivided conjugal property: The Court clarified that the defendants, as natural children of Antonio Centeno, were entitled to one-half of Antonio's hereditary portion from the conjugal property of Isaac Centeno and Melchora Arroyo that remained undivided. This one-half represented one-sixth of the whole conjugal property. The other half of Antonio's portion belonged to Melchora Arroyo. The remaining half of the undivided conjugal property, belonging to Melchora Arroyo, was to be divided among the plaintiffs and intervenors. On the action for partition: The Court held that an action for recovery of property based on the annulment of a partition and an action for partition of property declared to be undivided common property are not incompatible. Once the court declares that property belongs to parties in common and pro indiviso, it can order the partition thereof.
Main Doctrine
An extrajudicial partition agreement, upon judicial approval after proper notice and hearing, becomes a judicial partition, final and irrevocable, binding upon all parties who participated and acquiesced therein. Natural children, as acknowledged heirs, are entitled to inherit from their father and represent him in his inheritance, but their right to represent their father in the inheritance of their natural grandfather is not admitted by law.