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THE ROMAN CATHOLIC BISHOP OF TUGUEGARAO v. FLORENTINA PRUDENCIO

FACTS:

The Roman Catholic Bishop of Tuguegarao purchased a parcel of land in Baggao, Cagayan from the Spouses Cepeda, who obtained their title from Teodora Abad. Teodora obtained title over the land through an Extra-Judicial Partition of the Estate of Felipe Prudencio with Waiver of Rights. However, the children of Felipe Prudencio from his first marriage claimed that they were fraudulently excluded from the partition and filed a complaint for partition and reconveyance. They sought to have the land reconveyed and damages awarded.

The Regional Trial Court (RTC) ruled in favor of the children, declaring the Extra-Judicial Partition null and void. Petitioner appealed to the Court of Appeals (CA), but the CA affirmed the RTC's ruling, finding petitioner not a buyer in good faith. Petitioner filed a petition for reconsideration, which was denied. The Supreme Court denied the petition, emphasizing that the issue is the exclusion of the rightful heirs in the partition of the estate. The good faith or bad faith of the purchaser is immaterial in this case. The court ruled that the Extra-Judicial Partition did not validly pass ownership of the land to Teodora, as it excluded the legitimate heirs of Felipe. Thus, petitioner's title, derived from Teodora's title, is also invalid. The court affirmed the lower courts' rulings, ordering the reconveyance of the land to the respondents.

In another case, Felipe, who had two marriages, died intestate and left behind a parcel of land. Petitioner Jose filed an Extra-Judicial Settlement of Estate with Sale to purchase the land, but only the children from Felipe's first marriage were named as heirs in the settlement. Sofia, the child from Felipe's second marriage, opposed the settlement, arguing that she should also be included as an heir. The RTC dismissed Sofia's opposition, ruling that under Article 979 of the Civil Code, only the children from Felipe's first marriage should be considered as heirs. Sofia appealed to the CA, which reversed the RTC's ruling, stating that Sofia, being a child of Felipe, is entitled to inherit from his estate. Hence, petitioner filed a petition before the Supreme Court seeking review on certiorari.

ISSUES:

  1. Did the Extra-Judicial Partition validly pass ownership of the Cagayan lot to Teodora?

  2. Should the children of Felipe in his two marriages be included in the execution of the Extra-Judicial Partition?

  3. Is the Extra-Judicial Partition binding on all the heirs?

  4. Whether the Extra-Judicial Partition is void.

  5. Whether the sale between Teodora and Spouses Cepeda, and subsequently between Spouses Cepeda and petitioner are valid insofar as Teodora's share is concerned.

  6. Whether the partition of the Cagayan lot should be ordered.

  7. Whether respondents-appellees are entitled to their rightful shares in the Cagayan lot.

  8. Whether petitioner should reconvey a portion of the Cagayan lot to respondents-appellees.

  9. Whether Spouses Cepeda are required to return to petitioner the amount paid corresponding to the share of respondents-appellees.

RULING:

  1. The Extra-Judicial Partition did not validly pass ownership of the Cagayan lot to Teodora.

  2. The children of Felipe in his two marriages should be included in the execution of the Extra-Judicial Partition.

  3. The Extra-Judicial Partition is not binding on all the heirs.

  4. The Extra-Judicial Partition is void under Article 1409(1) as the cause, object, or purpose of the partition is contrary to law. It has no force and effect from the beginning and cannot be validated by time or ratification.

  5. The sale between Teodora and Spouses Cepeda is valid insofar as Teodora's share is concerned. Similarly, the subsequent sale between Spouses Cepeda and petitioner is also valid insofar as Teodora's share is concerned. Therefore, petitioner holds the share of the respondents-appellees under an implied constructive trust.

  6. The partition of the Cagayan lot should be ordered, deducting the conjugal share of Felipe as the surviving spouse. Felipe is entitled to one-half of the Cagayan lot as his conjugal share and one-fifth of the Cagayan lot as an heir of Elena.

  7. The Court held that respondents-appellees are entitled to their rightful shares in the Cagayan lot.

  8. Petitioner is ordered to reconvey a portion of the Cagayan lot to respondents-appellees as their pro indiviso share.

  9. Spouses Cepeda are directed to return to petitioner the amount paid corresponding to the share of respondents-appellees, with legal interest.

PRINCIPLES:

  • Articles 979, 980, and 981 of the Civil Code provide that all legitimate children shall inherit from their parents and participate in the settlement of the estate.

  • Rule 74, Section 1 of the Rules of Court states that an extrajudicial settlement by agreement between heirs is not binding upon any person who has not participated therein or had no notice thereof.

  • A settlement is considered null and void if it excludes entitled heirs who are entitled to equal shares in the partitioned property, and it is not covered by the provision of Rule 74, Section 1.

  • Rightful shares in an estate should be distributed among legal heirs in accordance with the law.