Title
Ignacia Gerona vs. De Guzman
Case Decision Date
G.R. No. L-19060 29 May 1964
Petitioners sought nulli!cation of a fraudulent deed and reconveyance of
their inheritance share, but the Supreme Court ruled their action was time-
barred due to constructive notice from the 1948 registration.
Jur.ph - Case Digest (G.R. No. L-19060)
Direct Answer Model - Detailed
Facts:
The case involves petitioners Ignacio Gerona, Maria Concepcion Gerona, Francisco
Gerona, and Del!n Gerona, who are the legitimate children of Domingo Gerona and
Placida de Guzman. Placida, the mother of the petitioners, passed away on August 9,
1941, and was a legitimate daughter of Marcelo de Guzman and his !rst wife, Teodora
de la Cruz. After the death of Teodora, Marcelo married Camila Ramos, with whom
he had several children, the respondents in this case: Carmen, Jose, Clemente,
Francisco, Rustica, Pacita, and Victoria De Guzman. Marcelo de Guzman died on
September 11, 1945. On May 6, 1948, the respondents executed a deed of "extrajudicial
settlement of the estate of the deceased Marcelo de Guzman," falsely claiming to be
the only surviving heirs, thereby excluding the petitioners, who were also forced
heirs. This fraudulent act led to the cancellation of the original transfer certi!cates of
title for seven parcels of land owned by Marcelo and the issuance of new titles solely
in the names of the respondents. The petitioners discovered this fraud only in 1957
and subsequently demanded their rightful share of the properties, which the
respondents refused. Consequently, the petitioners !led a complaint on September 4,
1958, seeking to nullify the extrajudicial settlement, reconvey their share of the
properties, and claim damages. The respondents countered that the petitioners'
mother was a spurious child and that the action was barred by the statute of
limitations. The trial court ruled in favor of the respondents, a"rming that the
petitioners' mother was legitimate but that the action had prescribed. This decision
was upheld by the Court of Appeals.
Issue:
1. Is the action for partition of the estate of Marcelo de Guzman barred by the
statute of limitations?
2. Did the petitioners have a valid claim to annul the deed of extrajudicial
settlement based on the alleged fraud?
Ruling:
The Supreme Court a"rmed the decision of the Court of Appeals, ruling that the
action for partition was indeed barred by the statute of limitations. The Court held
that the petitioners' claim to annul the deed of extrajudicial settlement was also time-
barred, as they failed to !le their complaint within the prescribed period following
the discovery of the alleged fraud.
Ratio:
The Court reasoned that while an action for partition among co-heirs generally does
not prescribe, this principle applies only when the defendants do not hold the
property under an adverse title. In this case, the respondents' execution of the
extrajudicial settlement and the subsequent issuance of new titles constituted an
assertion of an adverse title against the petitioners. The Court emphasized that the
statute of limitations begins to run from the moment an adverse title is asserted. The
registration of the deed of extrajudicial settlement on June 25, 1948, served as
constructive notice to the petitioners, marking the start of the four-year period
within which they could !le their action. The petitioners' complaint, !led on
November 4, 1958, was thus beyond the allowable period. The Court also noted that
the petitioners, upon reaching the age of majority, had a limited time to !le their
claims, which they failed to do. Therefore, the Court concluded that the petitioners'
action was barred by the statute of limitations, a"rming the lower courts' decisions.
