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Art 980 Heirs of Joaquin Teves VS Ca

The case involves a dispute over inheritance of land between heirs of Joaquin Teves who died intestate in 1953. Some heirs executed extrajudicial settlements to transfer their shares of the inherited land to their sister Asuncion Teves. However, one heir, Cresenciano Teves, did not sign the settlements and claimed his rightful share of the inheritance. The Supreme Court upheld the extrajudicial settlements signed by consenting heirs but also ruled that Cresenciano, through his son Ricardo, was entitled to his 1/8 share of one parcel of land according to the law on equal distribution of inheritance among children.

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244 views1 page

Art 980 Heirs of Joaquin Teves VS Ca

The case involves a dispute over inheritance of land between heirs of Joaquin Teves who died intestate in 1953. Some heirs executed extrajudicial settlements to transfer their shares of the inherited land to their sister Asuncion Teves. However, one heir, Cresenciano Teves, did not sign the settlements and claimed his rightful share of the inheritance. The Supreme Court upheld the extrajudicial settlements signed by consenting heirs but also ruled that Cresenciano, through his son Ricardo, was entitled to his 1/8 share of one parcel of land according to the law on equal distribution of inheritance among children.

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HEIRS OF JOAQUIN TEVES VS CA

GR No. 109963, October 13, 1999

FACTS:

Spouses Marcelina Cimafranca and Joaquin Teves died intestate and without debts
in 1943 and 1953, respectively. During their lifetime, the spouses own two parcels of
land registered in the name of Marcelina and another lot registered in the name of
Joaquin and his two sisters. However, Joaquin’s sisters died without issue, causing the
entire property to pass to him. After Marcelina and Joaquin died, their children
executed extrajudicial settlements purporting to adjudicate unto themselves the
ownership over the two parcels of land and to alienate their shares thereto in favor of
their sister Asuncion Teves for a consideration. The division of the subject lot was
embodied in two deeds. The first Deed of Extrajudicial Settlement and Sale was entered
into on June 13, 1956 while the second deed was executed on April 21, 1959. The
Deed of Extrajudicial Settlement and sale was executed on December 14, 1971. After
the death of Asuncion Teves, her children, private respondents, extrajudicially settled
her property, adjudicating unto themselves said lots.

However, Cresenciano Teves, one of the heirs was not a signatory to the two alleged
Deed of Extrajudicial Partition, and thru his son Ricardo contended that they should not
be affected by the sale to Asuncion Teves, and hence, be given back their share in the
inheritance.

ISSUE: Should the extrajudicial settlements be upheld?

Yes. An extrajudicial settlement is a contract and it is a well-entrenched doctrine


that the law does not relieve a party from the effects of a contract, entered into with all
the required formalities and with full awareness of what he was doing, simply because
the contract turned out to be a foolish or unwise investment. Therefore, although
plaintiffs-appellants may regret having alienated their hereditary shares in favor of their
sister Asuncion, they must now be considered bound by their own contractual acts.

But in the part of Cresenciano represented by his son Ricardo Teves, he is given 1/8
part of Lot 769-A because according to Art. 980 of the New Civil Code “ The children of
the deceased shall always inherit from him in their own right, dividing the inheritance in
equal shares”. Since they are all 8 in the family, the inheritance must be divided in
equal shares, thus Cresenciano thru his predescessor-in-interest must be him his share
and not to be subjected to the conveyance to Asuncion Teves and her children.

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