Petitioner
Rogelio Logrosa
Respondent
Spouses Cleofe
Citation
G.R. No. 217611
Court
Supreme Court
Division
Second Division
Ponente
Caguioa, J.
Decided
March 27, 2019

Summary

This case involves a partition dispute over eight parcels of land in Tagum City, Davao del Norte. Petitioner Rogelio Logrosa sought partition of properties allegedly co-owned with respondents since 1987, based on certificates of title and a notarized deed of sale showing co-ownership. Respondents Sps. Azares opposed, claiming they were sole owners and that petitioner was merely a trustee without financial contribution. Both the RTC and CA dismissed the partition complaint, finding insufficient evidence of co-ownership. The Supreme Court reversed, emphasizing that certificates of title create an indefeasible presumption of ownership that cannot be overcome by self-serving testimony alone. The Court found respondents' delayed assertion of sole ownership (after 20+ years) inconsistent with their claim and noted that certificates of title serve as the best proof of ownership. The SC directed partition proceedings, establishing that co-owners may compel partition regardless of how they acquired their title, whether through purchase or gratuity. The decision reinforces the primacy of registered titles in establishing property ownership rights.

Statutes applied

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By Intellegal Editorial Board · March 27, 2019

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