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SPS. DOMINADOR MARCOS v. HEIRS OF ISIDRO BANGI

FACTS:

On June 26, 1998, the heirs of Isidro Bangi and Genoveva Diccion filed a complaint against spouses Dominador Marcos and Gloria Marcos. The complaint sought the annulment of documents, cancellation of transfer certificates of titles, restoration of the original certificate of title, and recovery of ownership, along with damages. The complaint alleged that Isidro and Genoveva had purchased a portion of land from Eusebio Bangi. However, they later discovered that the title to the property had been transferred to the petitioners through a forged deed of absolute sale. As a result, the original certificate of title was canceled, and new certificates of title were issued in the petitioners' names. The respondents aimed to nullify the forged deeds of sale and restore the original certificate of title. The petitioners, on the other hand, denied the allegations and claimed ownership of the property. During the proceedings, a compromise agreement was reached between the respondents and some of the other defendants, leading to their dismissal from the case. The Regional Trial Court (RTC) ruled in favor of the respondents, declaring the forged deeds of sale as null and void, and restoring the original certificate of title. Displeased with the RTC's decision, the petitioners appealed to the Court of Appeals. The Court of Appeals affirmed the RTC's decision.

ISSUES:

  1. Whether the Court of Appeals committed reversible error in affirming the Regional Trial Court's decision upholding the validity of the Deed of Absolute Sale over the one-third portion of the subject property.

  2. Whether the oral partition among the heirs is valid and enforceable, and whether Eusebio already owned the subject property at the time he sold a portion of it to the spouses Isidro and Genoveva.

  3. Whether or not the accused is guilty beyond reasonable doubt of the crime of murder.

  4. Whether or not the accused had the intent to kill the victim.

  5. Whether or not the accused should be held liable for acts performed under the impulse of an uncontrollable fear of a real and imminent evil on his person.

RULING:

  1. The petition is denied. The Court of Appeals did not commit any reversible error in ruling that an oral partition of the estate of Alipio had already been effected by his heirs prior to the sale by Eusebio of the one-third portion of the subject property.

  2. The Court held that the oral partition among the heirs is valid and enforceable, and that Eusebio already owned the subject property at the time he sold a portion of it to the spouses Isidro and Genoveva. The lower courts correctly nullified the subsequent Deeds of Absolute Sale and Transfer Certificates of Title issued in favor of the petitioners. The Decision of the Court of Appeals affirming the nullification of the said Deeds of Absolute Sale and Transfer Certificates of Title is therefore affirmed.

  3. The accused is found guilty beyond reasonable doubt of the crime of murder.

  4. Yes, the accused had the intent to kill the victim.

  5. No, the accused cannot be excused from liability for acts performed under the impulse of an uncontrollable fear of a real and imminent evil on his person.

PRINCIPLES:

  • A question of law arises when there is doubt as to what the law is on a certain state of facts, while there is a question of fact when the doubt arises as to the truth or falsity of the alleged facts. For a question to be one of law, the same must not involve an examination of the probative value of the evidence presented by the litigants. The resolution of the issue must rest solely on what the law provides on the given set of circumstances.

  • Once it is clear that the issue invites a review of the evidence presented, the question posed is one of fact.

  • The determination of whether a partition has been effectuated requires an examination of the probative value of the evidence presented by the parties.

  • A petition for review under Rule 45 of the Rules of Court may only raise questions of law, and not questions of fact.

  • The Court cannot pass upon factual questions in a petition for review under Rule 45, even if it falls under any of the exceptions justifying a factual review of the lower court's findings.

  • Partition is the separation, division, and assignment of a thing held in common among those to whom it may belong.

  • Every act intended to put an end to indivision among co-heirs and legatees or devisees is deemed to be a partition.

  • Oral partition may be enforced in proper cases, where it has actually been consummated by the taking of possession in severalty and the exercise of ownership by the parties of the respective portions set off to each.

  • A parol partition may be sustained if the parties have acquiesced in and ratified the partition by taking possession in severalty, exercising acts of ownership with respect thereto, or otherwise recognizing the existence of the partition.

  • Guilt beyond reasonable doubt - In criminal cases, the prosecution must establish the guilt of the accused beyond reasonable doubt for a conviction to be valid.

  • Intent to kill - In murder cases, the prosecution must prove that the accused had the intention to kill the victim.

  • Insanity defense - Acts performed under the impulse of an uncontrollable fear of a real and imminent evil on the person of the accused does not excuse him from criminal liability.