In a case involving expropriation, the Supreme Court clarified the evidence needed to prove heirship for substitution in legal proceedings. The Court held that an unregistered Deed of Extrajudicial Settlement, while not binding on third parties regarding property adjudication, can still serve as evidence of heirship, especially when supported by other evidence. This ruling ensures that rightful heirs can claim just compensation even if the formal requirements of estate settlement have not been strictly followed.

From Unidentified Owner to Sole Heir: Validating Succession in Land Expropriation

The Republic of the Philippines, through the Department of Public Works and Highways (DPWH), initiated an expropriation case for the C-5 Northern Link Road Project. Initially, the complaint named an unidentified owner, “John Doe YY,” due to difficulties in identifying the registered titleholder of the property in Barangay Ugong, Valenzuela City. As the case progressed, Elena A. Macabagdal was identified as the registered owner. However, Elena passed away, leading to a legal question: Could her sister, Leonor A. Macabagdal, represented by Eulogia Macabagdal-Pascual, be properly substituted as the defendant in the expropriation case, especially given that the evidence of her heirship was an unregistered Deed of Extrajudicial Settlement?

The central legal issue revolved around the **sufficiency of evidence** to establish Leonor’s right to substitute Elena in the expropriation case. The Republic argued that the unregistered Deed of Extrajudicial Settlement was insufficient to prove Leonor’s claim as the sole heir, as it was neither registered with the Register of Deeds nor published in a newspaper of general circulation, as required by Sec. 1, Rule 74 of the Rules of Court. Leonor, on the other hand, contended that the substitution was proper, supported by various documents and the Republic’s acquiescence in recognizing her as the real party-in-interest.

The Regional Trial Court (RTC) ruled in favor of Leonor’s substitution, a decision upheld by the Court of Appeals (CA). The CA reasoned that the Republic had admitted that the subject property was registered in Elena’s name, making her the proper party defendant. With Elena’s death, her legal representative or sole heir could substitute her. The CA noted that Elena’s death certificate indicated she was single at the time of her death, with Leonor being her only remaining heir.

The Supreme Court affirmed the CA’s decision, emphasizing that the issue raised by the Republic was a **question of fact**, which is generally not reviewable in a petition for certiorari. A question of fact arises when there is doubt or difference as to the truth or falsehood of facts, requiring a calibration of evidence. The Court reiterated that it is not a trier of facts and will not re-examine evidence presented in lower courts.

The Supreme Court also highlighted that Leonor presented more than just the Deed of Extrajudicial Settlement. Witnesses, including Eulogia Macabagdal-Pascual and Nenita Pascual Ramota, testified, and documentary evidence, including Elena’s Death Certificate, was submitted. The Court noted the significance of the Republic’s initial position, which depended on a certification from the DPWH’s Project Director regarding the property’s identity. This indicated that the Republic’s primary concern was the land’s identity, not Leonor’s status as Elena’s heir.

Even if the Deed of Extrajudicial Settlement were the sole evidence, the Court clarified that its unregistered status does not negate its evidentiary value in establishing heirship. While Section 1, Rule 74 of the Rules of Court states that an unregistered extrajudicial settlement does not bind third parties regarding property adjudication, there is no prohibition against using the instrument to prove heirship. The Court stated:

“[T]here is no provision in the Rules of Court which states that ‘the instrument cannot be used to prove that one is an heir’ due to the sheer fact that it was not registered before the Register of Deeds.”

Building on this principle, the Court emphasized the **presumption of regularity and truthfulness** afforded to notarized documents. The Deed of Extrajudicial Settlement, being a notarized document, carries the presumption that its contents are truthful. This presumption placed the burden on the Republic to disprove Leonor’s claim as Elena’s sole surviving heir. The Court noted that the Republic failed to provide any evidence or allegation that Leonor was not Elena’s sole surviving heir.

In conclusion, the Supreme Court found no grave abuse of discretion on the part of the RTC in allowing Leonor’s substitution. The Court underscored that heirship can be established through various means, and the lack of registration of a Deed of Extrajudicial Settlement does not automatically invalidate its use as evidence, especially when corroborated by other evidence and unchallenged by contrary proof. This ruling provides clarity on the evidentiary requirements for establishing heirship in expropriation cases, ensuring that rightful heirs are not unjustly deprived of just compensation.

FAQs

What was the key issue in this case?	The key issue was whether an unregistered Deed of Extrajudicial Settlement is sufficient to prove heirship for the purpose of substitution in an expropriation case.
What is a Deed of Extrajudicial Settlement?	A Deed of Extrajudicial Settlement is a document used by heirs to divide the estate of a deceased person without going to court, provided there is no will and no debts.
Why did the Republic question Leonor’s substitution?	The Republic questioned Leonor’s substitution because the Deed of Extrajudicial Settlement she presented was not registered with the Register of Deeds, arguing it was insufficient proof of heirship.
What did the Court say about the unregistered Deed?	The Court clarified that while an unregistered deed does not bind third parties regarding property adjudication, it can still be used as evidence to prove heirship, especially when supported by other evidence.
What other evidence did Leonor present?	Leonor presented witnesses and Elena’s death certificate, in addition to the Deed of Extrajudicial Settlement, to support her claim as the sole heir.
What is the significance of a notarized document?	A notarized document carries a presumption of regularity and truthfulness of its contents, placing the burden on the opposing party to disprove the document’s claims.
What is grave abuse of discretion?	Grave abuse of discretion implies such capricious and whimsical exercise of judgment as is equivalent to lack of jurisdiction.
What was the Court’s final ruling?	The Supreme Court affirmed the CA’s decision, holding that the RTC did not commit grave abuse of discretion in allowing Leonor to substitute Elena as the party defendant in the expropriation case.

This case clarifies that proving heirship doesn’t solely depend on a registered Deed of Extrajudicial Settlement. Courts can consider other forms of evidence to establish the rightful heirs, promoting fairness and ensuring just compensation in expropriation cases. This decision protects the rights of heirs who may not have strictly complied with all the formal requirements of estate settlement but can still demonstrate their legitimate claim.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: REPUBLIC OF THE PHILIPPINES vs. LEONOR A. MACABAGDAL, G.R. No. 203948, January 22, 2020