- Petitioner
- Heirs of Ernesto Morales
- Respondent
- Agustin
- Citation
- G.R. No. 224849
- Court
- Supreme Court
- Division
- Second Division
- Ponente
- Reyes, Jr., J.
- Decided
- June 6, 2018
Summary
This case involves a partition dispute among heirs of Jayme Morales over inherited property Lot No. 9217-A. Respondent Astrid Morales Agustin sued petitioners (heirs of Ernesto Morales) for partition claiming co-ownership rights as granddaughter of the deceased. Petitioners defended that respondent's parents had already conveyed their successional rights to their father through various transactions evidenced by handwritten receipts. The RTC rendered summary judgment for respondent ordering equal partition among heir groups. The CA affirmed, but the Supreme Court reversed, finding that genuine issues of fact existed regarding the alleged conveyance of rights, making summary judgment improper. The Court also ruled that summary judgment cannot be rendered motu proprio without a motion from parties, violating procedural due process. The case was remanded for full trial, with the Court emphasizing that partition of inherited property must consider collation of all estate properties and cannot ignore genuine factual disputes about prior transactions among heirs.
Intellegal Wiki · Key Holding
Reversed and set aside the CA, holding that summary judgment was improper because a genuine issue of fact existed over the alleged conveyance of successional rights, that summary judgment cannot be rendered without a motion from a party, and that partition of an estate must account for collation of all the decedent's properties; the case was remanded for trial.
An editorially maintained summary of the rule this Supreme Court decision is cited for — not legal advice.