Delos Santos v. Delos Santos
REITERATIONFacts
The Antecedents: This case concerns the conjugal partnership properties of the late Spouses Emerenciano Delos Santos and Adalia Delos Santos. Adalia passed away in 1996, survived by her husband Emerenciano, their natural child Demy Alma Delos Santos, and adopted children Montano Delos Santos, Irene Angela D. Clemente, and Seatiel M. Delos Santos. Approximately seven years later, Emerenciano married Luz Delos Santos, with whom he had three children: Francis, Catherine, and Lorence. In 2009, Emerenciano and Luz, purporting to act on behalf of their minor children, executed an Extrajudicial Settlement of Estate with Waiver (EJSW) concerning two parcels of land with improvements. In this EJSW, Emerenciano and his minor children claimed to be the sole heirs of Adalia, and Emerenciano subsequently conveyed the entirety of these properties to Francis, Catherine, and Lorence. Following Emerenciano's death in 2011, Demy, Montano, Irene, and Seatiel discovered these conveyances and filed a complaint to annul the EJSW and subsequent deeds, asserting their rightful inheritance from Adalia's estate. Procedural History: Demy, Montano, Irene, and Seatiel filed a Complaint against Luz, Francis, Catherine, and Lorence for the annulment of the EJSW and a Deed of Waiver, Quitclaim and Transfer of Residential Buildings, and the cancellation of the new Transfer Certificates of Title (TCTs) and Tax Declarations (TDs) issued as a result. They argued that the conveyed properties were conjugal properties of Emerenciano and Adalia, and the exclusion of Adalia's legal heirs from their rightful shares rendered the conveyances void. They also contended that Emerenciano and his children from Luz misrepresented themselves as Adalia's sole heirs. Luz and her children countered by questioning the filiation of Demy, Montano, Irene, and Seatiel and asserting that the respondents were aware of the conveyances and had received other properties. The Regional Trial Court (RTC) ruled that the properties were conjugal, recognized Demy, Montano, Irene, and Seatiel as Adalia's legal heirs, and declared the deeds of conveyance void as they excluded the respondents. However, the RTC clarified that the conveyances might be valid concerning Emerenciano's share. The RTC ultimately annulled the EJSW and the Deed of Waiver, Quitclaim and Transfer of Residential Buildings and ordered the cancellation of the new TCTs and TDs, reverting them to their original titles. Luz and her children appealed to the Court of Appeals (CA), raising arguments of laches and prescription, but the CA affirmed the RTC's decision. Their subsequent motion for reconsideration was denied, leading to the present petition. The Petition: Petitioners Luz Delos Santos, Francis Delos Santos, Catherine Delos Santos, and Lorence Delos Santos 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. They argue that the RTC erred in acknowledging the respondents' heirship without a separate special proceeding, contending that filiation must be determined in such a proceeding. Petitioners also maintain that the respondents are estopped from questioning the extrajudicial settlement and conveyances because they were aware of them and had received other properties. Furthermore, they assert that the respondents' cause of action is barred by laches and prescription, as they failed to object during Emerenciano's lifetime. Finally, petitioners claim that the EJSW should be interpreted to uphold Emerenciano's intention to transfer his share of the conjugal properties to Francis, Catherine, and Lorence. The core of the petition is to overturn the lower courts' rulings that declared the EJSW and subsequent deeds void concerning the respondents' inheritance.
Issue(s)
I. Is a separate proceeding necessary before the trial court can acknowledge respondents' heirship? II. Did the courts a quo err in nullifying the EJSW and the Deed of Waiver, Quitclaim and Transfer of Residential Buildings, as well as the TCTs and TDs issued by virtue of the nullified deeds? III. Was respondents' cause of action already barred by laches and prescription?
Ruling
The Supreme Court partly granted the petition. It affirmed the CA's decision with modification, declaring the Extrajudicial Settlement of Estate with Waiver (EJSW) void only insofar as the settlement itself was concerned. The EJSW was declared valid only concerning the conveyances pertaining to Emerenciano Delos Santos' rightful share in the properties, subject to the liquidation of the conjugal partnership and the settlement and partition of the estates of Adalia Delos Santos and Emerenciano Delos Santos with the full participation of all heirs. The Court directed the Register of Deeds of Olongapo City to cancel TCT No. T-15438 and revert it to OCT No. P-1850, and to cancel TCT No. T-15439 in its entirety and revert it to TCT No. T-3337. It also directed the Office of the City Assessor of Olongapo City to cancel specific Tax Declarations and revert them to their original declarations.
Ratio Decidendi
On Issue I: Is a separate proceeding necessary before the trial court can acknowledge respondents' heirship? No, a separate proceeding is not necessary. The respondents asserted their rights as natural and adopted children of Adalia and sought to annul deeds that deprived them of their hereditary rights. They were not seeking to establish their heirship but were asserting a right they already possessed by operation of law as Adalia's children. The petitioners themselves raised questions regarding the respondents' succession rights, thereby voluntarily submitting the issue of heirship to the trial court. The RTC had already adjudged the issue based on the evidence presented. Furthermore, whether Demy was a natural or adopted child was inconsequential, as both statuses establish her as Adalia's legal heir under the law. The Court found no reason to deviate from the RTC's factual findings on the respondents' status as Adalia's legal heirs, which were supported by evidence. On Issue II: Did the courts a quo err in nullifying the EJSW and the Deed of Waiver, Quitclaim and Transfer of Residential Buildings, as well as the TCTs and TDs issued by virtue of the nullified deeds? No, the courts a quo did not err in nullifying the EJSW and Deed of Waiver, Quitclaim and Transfer of Residential Buildings, but only insofar as they excluded the respondents from their rightful shares. It is undisputed that the properties were conjugal properties of Emerenciano and Adalia. Upon Adalia's death, Emerenciano had a vested one-half undivided share, while the other half pertained to Adalia's estate, co-owned by Emerenciano and the respondents as her legal heirs. The EJSW misrepresented that Emerenciano and his second family were the sole heirs of Adalia, unlawfully excluding the respondents. Such an extrajudicial settlement is void and inexistent as it is contrary to law and Rule 74, Section 1 of the Rules of Court, which states that it is not binding upon those who did not participate or have notice. However, the conveyances made by Emerenciano are not totally void; they are valid to the extent of his undivided interest in the properties, which includes his one-half conjugal share and his inheritance from Adalia's estate. This is consistent with Article 493 of the Civil Code on co-ownership, which allows a co-owner to alienate their part, but the effect is limited to the portion allotted upon partition. The conveyances are further subject to the determination of the legitimes of all compulsory heirs in the settlement of Emerenciano's estate. Therefore, the nullification of the EJSW and the cancellation of the new titles and tax declarations were correct, but only to the extent that they prejudiced the respondents' shares, with Francis, Catherine, and Lorence becoming co-owners with the respondents pending proper liquidation and partition. On Issue III: Was respondents' cause of action already barred by laches and prescription? No, respondents' cause of action was not barred by laches and prescription. The courts a quo found that the respondents had no knowledge of the questioned documents until their father's death. Upon learning of the prejudice to their succession rights, they sought annulment within a reasonable time, negating laches. Furthermore, Article 1410 of the Civil Code explicitly states that an action for the declaration of the inexistence of a contract does not prescribe. The principle that laches and prescription cannot work against co-heirs deprived of their lawful participation in an estate also applies here. The Court reiterated that buyers of property that could not be validly sold become trustees for the benefit of the other heirs, who are not barred by prescription or laches.
Main Doctrine
An extrajudicial settlement that excludes co-heirs from their rightful share in the inheritance is void and inexistent. However, transfers pertaining to the undivided share of the conveying co-heir should be recognized as valid, subject to proper liquidation and partition, and further subject to the determination of legitimes of all compulsory heirs.