REPUBLIC OF THE PHILIPPINES vs. DAVID REY GUZMAN (SUCCESSION)

[G.R. No. 132964. February 18, 2000]

REPUBLIC OF THE PHILIPPINES, petitioner, vs. DAVID REY GUZMAN, represented by his Attorney-in-Fact, LOLITA G. ABELA, and the REGISTER OF DEEDS OF BULACAN, MEYCAUAYAN BRANCH, respondents.

BELLOSILLO, J.:

FACTS:

David Rey Guzman, a natural-born American citizen, is the son of the spouses Simeon Guzman, a naturalized American citizen, and Helen Meyers Guzman, an American citizen. In 1968 Simeon died leaving to his sole heirs Helen and David an estate consisting of several parcels of land located in Bagbaguin, Sta. Maria, Bulacan.

On 29 December 1970 Helen and David executed a Deed of Extrajudicial Settlement of the Estate of Simeon Guzman dividing and adjudicating to themselves all the property belonging to the estate of Simeon. 

On 10 December 1981 Helen executed a Quitclaim Deed assigning, transferring and conveying to her son David her undivided one-half (1/2) interest on all the parcels of land subject matter of the Deed of Extrajudicial Settlement of the Estate of Simeon Guzman. 

On 18 October 1989 David executed a Special Power of Attorney where he acknowledged that he became the owner of the parcels of land subject of the Deed of Quitclaim executed by Helen on 9 August 1989.

On 16 March 1994 a certain Atty. Mario A. Batongbacal wrote the Office of the Solicitor General and furnished it with documents showing that Davids ownership of the one-half (1/2) of the estate of Simeon Guzman was defective. On the basis thereof, the Government filed before the Regional Trial Court of Malolos Bulacan a Petition for Escheat praying that one-half (1/2) of David's interest in each of the subject parcels of land be forfeited in its favor.

On 11 July 1995 the trial court dismissed the petition holding that the two (2) deeds of quitclaim executed by Helen Meyers Guzman had no legal force and effect so that the ownership of the property subject thereof remained with her. The Government appealed the dismissal of the petition but the appellate court affirmed the court a quo.

As a rule, only a Filipino citizen can acquire private lands in the Philippines. The only instances when a foreigner can acquire private lands in the Philippines are by hereditary succession and if he was formerly a natural-born Filipino citizen who lost his Philippine citizenship. Petitioner therefore contends that the acquisition of the parcels of land by David does not fall under any of these exceptions. It asserts that David being an American citizen could not validly acquire one-half (1/2) interest in each of the subject parcels of land by way of the two (2) deeds of quitclaim as they are in reality donations inter vivos. 

David maintains, on the other hand, that he acquired the property by right of accretion and not by way of donation, with the deeds of quitclaim merely declaring Helens intention to renounce her share in the property and not an intention to donate.

ISSUES:

(1) Whether Helen validly repudiated her right to inherit from the decedent.

(2) Whether the petition for escheat filed by the Government will prosper.

RULING:

(1) There is no valid repudiation of inheritance as Helen had already accepted her share of the inheritance when she, together with David, executed a Deed of Extrajudicial Settlement of the Estate of Simeon Guzman in 1970 dividing and adjudicating between the two of them all the property in Simeon’s estate.

Article 1056 of the Civil Code provides that “the acceptance or repudiation of an inheritance, once made is irrevocable and cannot be impugned, except when it was madethrough any of the causes that vitiate consent or when an unknown will appears.”

In this case, there is no showing that Helen's acceptance of her inheritance from Simeon was made through any of the causes which vitiated her consent nor is there any proof of the existence of an unknown will executed by Simeon.

Thus,pursuant to Article 1056, Helen cannot belatedly execute an instrument that has the effect of revoking or impugning her previous acceptance of her one-half share of the subject property from Simeon’s estate. Hence, the quitclaim deeds that she executed eleven years after she had accepted the inheritance have no legal force and effect.

(2) No, the nullity of the repudiation does not ipso facto operate to convert the parcels of land into res nullius to be escheated in favor of the Government. The repudiation being of no effect whatsoever the parcels of land should revert to their private owner, Helen, who, although being an American citizen, is qualified by hereditary succession to own the property subject of the litigation.