Heirs of Ignacio Conti v. Court of Appeals

Summary

The Supreme Court affirmed the right of alleged collateral heirs of deceased co-owner Lourdes Sampayo to demand partition of co-owned real property without prior estate settlement. The Court held that property title passes immediately to heirs upon death of intestate owner under Civil Code provisions, allowing them to exercise co-ownership rights including partition. Despite the destruction of civil registry records by fire, the Court found that baptismal certificates constituted admissible public documents proving filiation when corroborated by testimonial evidence. The case established that ordinary partition between co-owners does not require the publication requirements applicable to estate settlements, and that preponderance of evidence standard applies to proving heirship in partition actions. This decision reinforced the immediate vesting of inheritance rights and the accessibility of partition remedies for rightful heirs.