Facts:

The case revolves around a Petition for Review on Certiorari filed by Benzon O. Aldemita (petitioner) against the Heirs of Melquiades Silva, represented by Ramon G. Villordon, Jr. (respondents). The origin of the dispute traces back to a Complaint for Quieting of Title that respondents filed on November 18, 1998, with the Regional Trial Court (RTC) of Cebu City, which was assigned to Branch 11 under Civil Case No. CEB-23011. Petitioner Aldemita filed a verified Answer on January 14, 1999, with special and affirmative defenses, as well as counterclaims. Throughout the proceedings, several motions were filed, including a motion to declare certain parties in default and motions for pre-trial.

The pre-trial, conducted on August 12, 1999, revealed critical admissions from petitioner, including acknowledging that Lot 11330 of Pcs-945 in Minglanilla, Cebu, was registered under the name of Melquiades Silva, and that the respondents had actual physical possession of the property. Aldemit

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Facts:

Initiation and Filing of the Case

• A Complaint for Quieting of Title was filed on November 18, 1998 by the Heirs of Melquiades Silva, represented by Ramon G. Villordon, Jr., initiating the dispute over Lot No. 11330 of Pcs-945 (Talisay-Minglanilla Estate) in Cebu City.
• The verified complaint was filed with the Regional Trial Court (RTC), Cebu City on November 25, 1998, and allocated to Branch 11 under Civil Case No. CEB-23011.
• The case involved conflicting claims between the respondents (Heirs of Melquiades Silva) and the petitioner, Benzon O. Aldemita, along with co-defendants, including the Heirs of Dionisia Vda. De Zabate.

Pleadings and Preliminary Motions

• Petitioner Aldemita filed a verified Answer with Special and Affirmative Defenses, Counterclaim, and Cross-claim on January 14, 1999.
• Following a substitution due to the death of respondent Emilia Deiparine (last seen on September 15, 1998), petitioner filed an Urgent Motion on April 22, 1999 to declare certain defendants (Roger and Josephine Deiparine) in default and to set the case for pre-trial, which was granted by the RTC on April 30, 1999.

Pre-trial Proceedings and Stipulations of Facts

• On August 12, 1999, during the pre-trial, the parties reached several critical stipulations:
• Petitioner Aldemita admitted that Lot No. 11330 of Pcs-945 was registered in the name of Melquiades Silva, as evidenced by Transfer Certificate No. T-18993 and Tax Declaration No. 25845-R.
• He acknowledged that the respondents were in actual physical possession of the lot, except for a 2,000-square-meter portion claimed by him.
• Petitioner recognized that the document titled “Kalig-onan sa Palit” (Exhibit C), allegedly executed on March 15, 1949 by Melquiades Silva in favor of Dionisia Vda. De Zabate, was a forgery, although he maintained that another document (“Kalig-onan sa Panagpalit nga Dayon” - Exhibit 1) and its subsequent confirmation (Exhibit 2) were genuine.

Investigation of Questioned Documents

• The RTC, on October 25, 1999, appointed the PNP Regional Crime Laboratory Office VII as a court commissioner to examine the authenticity of the signatures on Exhibit 1 and Exhibit 2.
• A Questioned Document Report was submitted on February 10, 2000 by Document Examiner Romeo Oliva Varona, and petitioner filed his Comment on the report on April 3, 2000.
• On September 15, 2000, the court adopted Varona’s findings as established findings of fact.

Subsequent Developments and Motions

• Petitioner further engaged in procedural maneuvers by filing a Position Paper on February 8, 2001, followed by a change in counsel from Atty. Manuel S. Paradela to Atty. Rodolfo A. Ugang, Sr. in early April 2001.
• On April 6, 2001, petitioner filed a Motion to Dismiss for lack of cause of action, contending that the respondents should have first been declared heirs through a special proceeding before they could sue.
• The RTC denied the Motion to Dismiss on April 20, 2001, basing its conclusion on untimeliness and on the premise that the Complaint sufficiently stated a valid cause of action.

RTC Decision and Findings

• On August 20, 2001, the RTC rendered its Decision:
• Declaring the respondents as the rightful and absolute owners of Lot No. 11330 of Pcs-945.
• Declaring the documents “Kalig-onan sa Palit” (Exhibit C), “Kalig-onan sa Panagpalit nga Dayon” (Exhibit 1), the Deed of Confirmation of Previous Deed of Sale (Exhibit 2), and the Deed of Absolute Sale executed by Emilia Deiparine (Exhibit 3) null and void due to forgery and lack of evidentiary support.
• Ordering petitioner Aldemita to respect the respondents’ title and vacate the premises.

Appeal Before the Court of Appeals

• Petitioner appealed the RTC decision, challenging:
• The declaration of the respondents as the true owners despite alleged deficiencies in proving their status as legal heirs.
• The nullification of the questioned documents and the subsequent injunction ordering respect for respondents’ title.
• On November 22, 2004, the Court of Appeals (CA) affirmed the RTC decision in toto and dismissed the petitioner’s appeal, with costs ordered against petitioner.

Issue:

Whether the RTC and the CA erred in declaring the respondents as the rightful and absolute owners of the property despite petitioner’s contention that the respondents had not fully established their status as legal heirs through a formal court proceeding or appointment of an administrator.

• The issue includes whether the lack of a separate action declaring heirship before instituting the quieting action affects standing as real parties-in-interest.

Whether the RTC and subsequently the CA erred in declaring as null and void the documents (allegedly “Kalig-onan sa Panagpalit nga Dayon,” the Deed of Confirmation, and the Deed of Absolute Sale) based on findings of forgery, notwithstanding petitioner’s assertion that some of these might qualify as ancient documents exempt from authentication proceedings.

• Central to the issue is the determination of the documents’ authenticity and their probative value as sources of title.

Whether petitioner’s Motion to Dismiss, filed after the case was submitted for decision, was properly considered, considering the Rules on Civil Procedure which mandate that a motion to dismiss for lack of cause of action be filed within a prescribed period.

• This issue further examines whether the defense was waived by petitioner’s untimely invocation.

• Whether the failure of petitioner to produce evidence substantiating the due execution and authenticity of the questioned documents led to the binding findings of forgery by the court-appointed document examiner.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)