**Casilang v. Casilang-Dizon: A Case of Property Succession and Ownership in the Philippine Supreme Court**
### Facts:
The case revolves around a dispute concerning the ownership and possession of three parcels of land located in Barangay Talibaew, Calasiao, Pangasinan, inherited from the late spouses Liborio Casilang and Francisca Zacarias. Liborio passed away in 1982, and Francisca followed shortly after. Ireneo and Bonifacio, two of their eight children, also predeceased their siblings. Ireneo’s heirs, claiming ownership of Lot No. 4618 through a Deed of Extrajudicial Partition with Quitclaim dated April 3, 1997, triggered a series of legal actions culminating in this Supreme Court decision.
Initial proceedings began with an unlawful detainer complaint filed by Rosario (Ireneo’s daughter) against her uncle, Jose, aimed at evicting him from Lot No. 4618. The Municipal Trial Court (MTC) ruled in favor of Rosario, a judgment seemingly bolstering her claim through a tax declaration in Ireneo’s name.
In response, Jose and other heirs of Liborio initiated a separate action in the Regional Trial Court (RTC) of Dagupan City to annul the Deed of Extrajudicial Partition and assert ownership and possession rights over Lot No. 4618. The RTC sided with Jose, recognizing the validity of a verbal partition among the heirs, wherein Jose was allocated Lot No. 4618.
Rosario appealed to the Court of Appeals (CA), which reversed the RTC’s decision, largely relying on the earlier MTC ruling in the unlawful detainer case. Unsatisfied, Jose’s heirs brought the matter to the Supreme Court.
### Issues:
1. Whether the CA erred in basing its decision on the MTC’s ruling in an unlawful detainer case which is limited to issues of possession.
2. Whether the oral partition among Liborio’s heirs, designating Lot No. 4618 to Jose, is valid and enforceable.
3. Whether tax declarations and receipts alone can be considered conclusive proof of ownership.
### Court’s Decision:
The Supreme Court ruled in favor of Jose’s heirs, reinstating the RTC’s decision. It held that:
1. Ejectment proceedings are confined to questions of possession and do not conclusively resolve ownership disputes. Therefore, the CA erred in relying exclusively on the MTC’s findings regarding ownership based on an ejectment case.
2. An oral partition, confirmed by the parties’ subsequent actions, such as taking possession of the allotted properties, is valid and enforceable. The Court found credible evidence of such a partition, with Jose being assigned Lot No. 4618.
3. Tax declarations and receipts, while relevant, are not conclusive evidence of ownership, especially when not accompanied by actual possession indicative of ownership.
### Doctrine:
– The distinction between a summary action of ejectment and a plenary action for recovery of possession or ownership is fundamental in Philippine law. An ejectment suit does not conclusively determine the issue of ownership.
– An oral partition among heirs is valid and can be enforced, especially when supported by subsequent acts confirming the partition.
– Tax declarations and receipts are not conclusive proof of ownership but are merely an indicia of a claim of ownership.
### Class Notes:
1. **Ejectment vs. Ownership**: An unlawful detainer or forcible entry case (ejectment case) focuses solely on the issue of possession, not ownership. The determination of ownership in such cases does not preclude later contests over title in appropriate actions.
2. **Oral Partition Validity**: An oral agreement for the partition of property among heirs is valid and enforceable if confirmed by their subsequent actions, such as taking possession according to the agreed partition.
3. **Proof of Ownership**: While tax declarations and payment of taxes are indicators of a claim of ownership, they do not, by themselves, establish ownership. Actual possession under a claim of ownership is a crucial element.
### Historical Background:
The case reflects the common practice in the Philippines of settling estates through verbal agreements among heirs, especially in locales with closely-knit family structures. It underscores the legal system’s recognition of customary practices in property distribution among heirs, balanced with the need for formal documentation and adjudication in disputes.
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