Delmolin-Paloma v. Delmolin-Magno
REITERATIONFacts
The Antecedents: Spouses Santiago and Eulalia Delmolin were the parents of Ester, Justina, and the late Cristobal. Santiago was the registered owner of a parcel of land. On August 28, 1967, Santiago allegedly sold a 300-square meter portion of the land to Justina. This sale was registered on August 13, 2000, after Justina executed a Kasulatan ng Pagpapatunay stating the sale covered 684 square meters, leading to the cancellation of Santiago's title and issuance of a new one in Justina's name. Ester constructed her house on the land in 1980. In 1984, Justina occupied their father's house. Four days after Santiago's interment, Justina gave Ester a copy of the Deed of Sale, which was the first time Ester learned of it. Ester then requested partition of the land among herself, Justina, and the heirs of Cristobal. Procedural History: The dispute was brought before the Sangguniang Barangay, resulting in a Certificate of Agreement for partition (342 sqm for Justina, 171 sqm for Ester, 171 sqm for Abigail). Justina refused to sign. An agreement of partition dated August 30, 1999, with the same terms, was approved by the Land Management Bureau. Justina later refused to implement the partition. The matter was again referred to the Sangguniang Barangay in 2008, leading to a "Katibayan Upang Makadulog sa Hukuman." On January 8, 2010, respondents filed a petition for annulment of Justina's title and judicial partition of Santiago's estate before the RTC. The RTC ruled in favor of the respondents, declaring the deed of sale null and void concerning Ester and Cristobal's shares and directing partition into three equal portions. The CA affirmed the RTC decision. The Petition: Petitioners assail the CA's affirmation of the RTC ruling, arguing that the court erred in ruling upon misjoined causes of action (annulment of title and partition) and in declaring the deed of sale partially null and void. They also question the directive for partition.
Issue(s)
Whether the Court of Appeals erred in affirming the RTC ruling declaring the Deed of Sale dated August 28, 1967, as partially null and void. Whether the Court of Appeals erred in affirming the RTC ruling directing the partition of the subject lot. Whether the RTC and CA erred in ruling upon misjoined causes of action for annulment of title and partition.
Ruling
The petition is denied. The assailed Decision and Resolution of the Court of Appeals are affirmed. The Deed of Sale dated August 28, 1967, is declared null and void insofar as the shares of Ester Delmolin-Magno and the heirs of Cristobal Delmolin are concerned. The subject lot is ordered to be partitioned into three equal portions among Justina Delmolin-Paloma, Ester Delmolin-Magno, and the heirs of Cristobal Delmolin.
Ratio Decidendi
On the nullity of the Deed of Sale: The Court found no merit in the petitioners' contention that the RTC erred in ruling on the validity of the sale, even if it was not specifically prayed for. The complaint contained a general prayer for "other relief and remedies under the premises as may be deemed just and equitable," which justifies granting a relief not specifically prayed for if warranted by the facts and evidence. The alleged deed of sale was the basis of the petitioners' claim of ownership, thus its validity could be ruled upon. The Court deferred to the factual findings of the lower courts, which found the sale doubtful. The fact that Santiago applied for a free patent over the property in his name after the alleged sale in 1967, and the unexplained 33-year delay in registering the sale, cast serious doubt on its veracity. Furthermore, Justina unilaterally expanded the scope of the sale from 300 to 684 square meters through a Kasulatan ng Pagpapatunay, which was deemed a self-serving declaration. On the partition of the lot: The Court affirmed the RTC's directive for partition. It was established that Ester, Justina, and Cristobal were legitimate children of Santiago and Eulalia and were thus entitled to inherit from Santiago in equal shares pursuant to Articles 979, 980, and 981 of the Civil Code. The lower courts' findings that respondents were deprived of their rightful share and that the lot should be divided equally among the heirs were supported by substantial evidence and were accorded great respect and finality. On the misjoinder of causes of action: The Court reiterated that a misjoinder of causes of action is not a ground for dismissal under Section 6, Rule 2 of the Rules of Court. Such misjoined causes of action may be severed and proceeded with separately, but if there is no objection to the improper joinder or the court does not motu proprio direct a severance, then there exists no bar in the simultaneous adjudication of all the erroneously joined causes of action, provided the court has jurisdiction over all of them. In this case, the petitioners did not object to the joinder, and the court had jurisdiction over both the action for annulment of title and the action for partition. The Court also cited Sps. Villafria v. Plazo, which held that asking for the annulment of transfers of property could be achieved in an action for partition.
Main Doctrine
A misjoinder of causes of action is not a ground for dismissal and may be simultaneously adjudicated if the court has jurisdiction over all causes of action and no objection is raised.