Facts:

On December 16, 2005, a complaint for Annulment and Quieting of Title was filed before the Regional Trial Court (RTC) of Angeles City, Branch 59, by a group of petitioners consisting of Leticia Naguit Aquino, Melvin Naguit, Rommel Naguit, Elma Naguit Tayag, Yssel L. Naguit, Rosalina Naguit Aumentado, Rizel Naguit Cunanan, Caridad Naguit Parajas, Millie Naguit Florendo, Marnel Naguit, Eduardo Naguit, Jose Naguit, Zoilo Naguit, and Amelia Naguit Dizon, with Yssel L. Naguit acting as the representative. The petitioners claimed they were the rightful heirs of the late Epifanio Makam and Severina Bautista, asserting ownership of a 557-square meter house and lot in Magalang, Pampanga, acquired through a Deed of Sale dated April 20, 1894. They asserted that they and their predecessors had continuously possessed the property for over a hundred years, paying real estate taxes and developing it for habitation. However, in June 2005, the petitioners received demand letters from respondents

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Facts:

Parties and Nature of the Case

• Petitioners: Leticia Naguit Aquino, Melvin Naguit, Rommel Naguit, Elma Naguit Tayag, Yssel L. Naguit, Rosalina Naguit Aumentado, Rizel Naguit Cunanan, Caridad Naguit Parajas, Millie Naguit Florendo, Marnel Naguit, Eduardo Naguit, Jose Naguit, Zoilo Naguit, and Amelia Naguit Dizon, represented by Yssel L. Naguit.
• Respondents: Cesar B. Quiazon, Amanda Quiazon, Jose B. Quiazon, and Reynaldo B. Quiazon, represented by Jaime B. Quiazon.
• The case is an action for the quieting of title involving disputed ownership of a house and lot in Magalang, Pampanga, covering 557 square meters.

Allegations of the Petitioners

• The petitioners claim to be the heirs of the late Epifanio Makam and Severina Bautista who allegedly acquired the property by a Deed of Sale dated April 20, 1894.
• They assert that, through successive possession spanning over 100 years, including constructing houses and timely payment of real estate taxes, they maintained open, continuous, adverse, and notorious possession of the property.
• In June 2005, petitioners received demand letters from the respondents asserting ownership and demanding vacancy of the premises.
• Petitioners further contended that the title registered in the names of the respondents under Transfer Certificate of Title (TCT) No. 213777-R was invalid, ineffective, voidable, or unenforceable, and they prayed for its cancellation and the issuance of a new title in their favor.

Respondents’ Defense and Counterclaims

• Respondents contended that they were the absolute owners of the subject property as evidenced by TCT No. 213777-R, which they inherited from their predecessor Fausta Baluyut.
• They argued that the petitioners’ deed of sale was spurious and could not prevail over the Land Registration Decree No. 122511 (dated June 28, 1919) and subsequent land registration proceedings that awarded and decreed title in favor of respondents’ predecessor.
• Respondents also raised affirmative defenses including prescription, laches, and res judicata—citing an earlier similar case (Civil Case No. 5487) which had been dismissed.

Proceedings at the Trial and Appellate Levels

• The complaint was originally filed on December 16, 2005 before RTC Branch 59, Angeles City, which later dismissed the petition on July 14, 2008, holding that the petitioners lost all right from the issuance of a valid OCT derived from the 1919 decision.
• The RTC also denied the petitioners’ motion for reconsideration on December 22, 2008, emphasizing that the petition failed to state a cause of action.
• The Court of Appeals (CA) affirmed the dismissal in its March 13, 2012 decision, holding that under Section 6, Rule 16 of the Rules of Court the trial court was allowed to hold a preliminary hearing and consider evidence on the affirmative defense of lack (or failure) of cause of action.
• During the proceedings, petitioners opted not to adduce rebutting evidence at the preliminary hearing, insisting that only the allegations in the complaint should be considered.

Evidence and Documents Presented

• Respondents produced documentary evidence including:
• The June 28, 1919 decision in Cadastral Case No. 5 and its English translation.
• Land Registration Decree No. 122511.
• Original Certificate of Title (OCT) No. RO-1138 (11376) and related partition documents.
• TCT No. 213777-R as evidence of the valid registration of their title.
• Petitioners, while relying solely on the allegations contained in their complaint, contended that their deed of sale was genuine and should be taken as hypothetically admitted in determining the sufficiency of cause of action.

Issue:

Whether the trial court, and subsequently the CA, erred by receiving and considering evidence external to the complaint in determining the sufficiency of the petitioners’ cause of action for quieting title.

• Petitioners argued that solely the allegations in the complaint should be examined to determine if a cause of action exists.
• They maintained that the trial court was precluded from considering external facts by conducting a preliminary hearing on the ground of failure to state a cause of action.

Whether the application of Section 6, Rule 16 of the Rules of Court, which permits a preliminary hearing on affirmative defenses, properly extended to the ground of “lack of cause of action” or “failure to state a cause of action.”

• Respondents contended that the rule allowed the trial court to consider additional evidence in resolving affirmative defenses and that they had been estopped from later asserting that only the complaint’s allegations should be considered.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)