Sunday, January 19, 2020

[CASE DIGEST] EMILIANA BAUTISTA, as heir of the late MANUEL BAUTISTA and EVANGELINE BAUTISTA vs. HON. JUSTICES CAROLINA C. GRINO-AQUINO, MANUEL T. REYES, AND JAIME M. LANTIN in their capacity as Justices of the Special First Division of the Court of Appeals, HON. PEDRO JL. BAUTISTA, in his capacity as Presiding Judge of the Court of First Instance of Rizal, Branch III, Pasay City, MANOLITO BAUTISTA, BENJAMIN DE GUZMAN, BETTY N. BAUTISTA alias BEATRIZ BAUTISTA, NELIA N. BAUTISTA, GLORIA N. BAUTISTA, CLARITA N. BAUTISTA and ROSALINA BAUTISTA (G.R. No. L-79958)

October 28, 1988 

Ponente: Gancayco, J. 

FACTS:
 
·         Manuel Bautista inherited a parcel of land from his father Mariano. Subsequently, Manuel contracted marriage with Juliana Nojadero, with whom he had children (herein private respondents). 

·         Manuel contracted a second marriage after his first wife Julian Nojadero passed away. Manuel and his second wife, Emiliana Tamayo-Bautista, had an only child, Evangeline Baustista.

·         In the meantime, a Deed of Extrajudicial Partition was executed between Nojadero's heirs and (allegedly) Manuel involving the land which the latter had inherited from his father. Manuel denied ever participating in the extrajudicial partition.

·         Upon registration of the Deed of Extrajudicial Partition, Manuel's title was cancelled and in lieu thereof, a new one was issued.

·         Later on, all those who took part in the partition of the property (except Manolito) executed a Deed of Absolute Sale in favor of Manolito. The latter then re-sold the property back to his other co-respondents, resulting in the issuance of multiple titles. 

·         Manuel disputed the partition of his property, and so a case was filed to render such partition null and void. 

·         The case was dismissed by the trial court upon the NBI's findings that Manuel's signature in the Deed of Extrajudicial Partition was authentic. The dismissal was affirmed by the CA.
·         Hence, the instant petition. 

·         Manuel's arguments: (a) He did not sign the Deed of Extrajudicial Partition; (b) said Deed was void ab initio because it was executed in violation of the prohibition on the extrajudicial partition of future inheritance; and (c) the trial court and CA erred in affirming the validity of the subject Deed because they essentially authorized the preterition of Manuel's daughter from his second marriage, Emiliana, who was excluded from the partition.

RULING: 

Petition granted. Subject Deed of Extrajudicial Partition involving Manuel's land is null and void ab initio.

Whether the property of Manuel, the surviving spouse from his first marriage, be the subject of an extrajudicial partition of the estate of his deceased wife? – NO.

·         Regardless of whether Manuel's signature in the Deed of Extrajudicial Partition is authentic, an examination of the document based on admitted and proven facts renders the document fatally defective.

Not the dead wife's property

·         The extrajudicial partition was supposed to be a partition without court intervention of the estate of the late Juliana Nojadera, first wife of Manuel Bautista, constituting the subject property. In the same document Manuel Bautista appears to have waived his right or share in the property in favor of private respondents.

·         However, the property subject matter of said extrajudicial partition does not belong to the estate of Juliana Nojadera. It is the exclusive property of Manuel Bautista who inherited the same from his father Mariano Bautista.
·         Under Section 1, Rule 74 of the Rules of Court an extrajudicial settlement of the Estate applies only to the estate left by the decedent who died without a will, and with no creditors, and the heirs are all of age or the minors are represented by their judicial or legal representatives. If the property does not belong to the estate of the decedent certainly it cannot be the subject matter of an extrajudicial partition.

·         In the present case,  the subject property does not belong to the estate of Juliana Nojadera. Therefore, the Deed of Extrajudicial Partition is void ab initio being contrary to law. 

·         To include in an extrajudicial partition property which does not pertain to the estate of the deceased would be to deprive the lawful owner thereof of his property without due process of law. Only property of the estate of the decedent which is transmitted by succession can be the lawful subject matter of an extrajudicial partition. In this case, the said partition obviously prejudices the right of Manuel Bautista as exclusive owner of the property.

Preterition of daughter from second marriage

·         If the Deed of Extrajudicial Partition were to be deemed valid, then it would result in the preterition of the right of Evangeline Bautista as a compulsory heir of Manuel Bautista, daughter of the latter by his second marriage. 

·         It is difficult to believe that Manuel Bautista would wittingly overlook and ignore the right of her daughter Evangeline to share in the said property. It is not surprising that he denied signing the said document.
·         Moreover, private respondents knew Evangeline Bautista who is their half-sister to be a compulsory heir. The court finds that her preterition was attended with bad faith, hence the said partition must be rescinded.

Clever scheme hatched by children from first marriage

·         After the execution of said extrajudicial partition and issuance of the title in their names, private respondents except Manolito Bautista in turn executed a deed of absolute sale of the property in favor of the latter in whose name the title was also issued.

·         Soon thereafter another deed of sale was executed this time by Manolito Bautista selling back the same property to private respondents in whose names the respective titles were thus subsequently issued.
·         This series of transactions between and among private respondents is an indication of a clever scheme to place the property beyond the reach of those lawfully entitled thereto.

Prohibition on partition of future inheritance

·         The subject extrajudicial partition cannot constitute a partition of the property during the lifetime of its owner, Manuel Bautista. Partition of future inheritance is prohibited by law.

Imprescriptibility of cause of action

·         The petitioners' right to sue their co-owners for partition of the property is imprescriptible. 

·         But even assuming that the present action were prescriptible, petitioners Emiliana Bautista and Evangeline Bautista, who are not parties to the said instrument, discovered the same only soon before they filed the complaint in court. So certainly, the action had not prescribed yet.