Facts:

The case involves Elvira T. Arangote as the petitioner against respondents Martin Maglunob, Lourdes S. Maglunob, and Romeo Salido. The dispute concerns a parcel of land, specifically Lot 12897, with an area of 982 square meters located in Maloco, Ibajay, Aklan. Elvira, married to Ray Mars E. Arangote, was the registered owner of the lot based on Original Certificate of Title (OCT) No. CLOA-1748, which was issued on March 26, 1993, by the Secretary of the Department of Agrarian Reform (DAR). The background of ownership traces back to Esperanza Maglunob-Dailisan, Elvira's source of title, who inherited it from her uncle Victorino Sorrosa through a notarized Partition Agreement executed on April 29, 1985, among his heirs. After declaring the property under her name for tax purposes, Esperanza executed a Last Will and Testament in 1985 bequeathing the property to Elvira and Ray Mars, although it was never probated.

In 1986, Esperanza executed an Affidavit relinquishing her righ

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Facts:

Procedural History

• The case originated with a complaint for Quieting of Title, Declaration of Ownership and Possession, Damages with Preliminary Injunction, and issuance of a Temporary Restraining Order filed by petitioner Elvira T. Arangote and her husband against respondents.
• The trial court (MCTC) initially ruled in favor of the petitioner and her husband by declaring them the true and lawful owners of the subject property.
• Respondents appealed the MCTC Decision to the RTC, which reversed the ruling and declared respondents and the other heirs of Martin Maglunob as the lawful owners and possessors of the entire subject property, ordering the petitioner to turn over possession and pay costs.
• A Motion for New Trial or Reconsideration was subsequently filed by the petitioner before the RTC, but it was denied.
• The petitioner and her husband then filed a Petition for Review with the Court of Appeals, challenging the RTC Decision on several grounds.
• The Court of Appeals, in its Decision and subsequent Resolution, affirmed the RTC ruling.
• Finally, the petitioner elevated the case to the Supreme Court through a Petition for Review on Certiorari under Rule 45 of the 1997 Rules of Civil Procedure.

Factual Background and Property Transactions

• The subject property is Lot 12897, with an area of approximately 982 square meters, located in Maloco, Ibajay, Aklan.
• Petitioner’s claim is anchored on a Certificate of Land Ownership Award (OCT No. CLOA-1748) issued in her name on 26 March 1993 and registered on 20 April 1993, which she argues is beyond the one-year period allowable for collateral attack on a Torrens title.
• The property’s origin involves multiple instruments and partitions:
• A notarized Partition Agreement dated 29 April 1985, by which Esperanza Maglunob (the grand-aunt) allocated the subject property to herself for real property tax purposes, and subsequently the property was declared in Esperanza’s name through Tax Declaration No. 16218.
• Two additional documents executed by Esperanza:
• A Last Will and Testament dated 24 June 1985, bequeathing the property in favor of petitioner and her husband (which was never probated).

ii. An Affidavit dated 9 June 1986 in which Esperanza renounced, relinquished, waived, and quitclaimed her rights, share, interest, and participation in the property in favor of the petitioner and her husband.

Issues in the Proceedings

• The conflicting factual findings between the trial court (MCTC) and the RTC regarding the origin and extent of the subject property.
• Whether Esperanza’s Affidavit, which purportedly acted as a donation of her one-third share to petitioner and her husband, was valid given the legal requisites for a donation of immovable property.
• Whether the issuance and subsequent registration of OCT No. CLOA-1748 in favor of the petitioner, outside the one-year period for collateral attack, can be invalidated through the counterclaim raised by the respondents.
• Whether the RTC and the Court of Appeals erred in rejecting the petitioner’s claim to be considered possessors in good faith, thus forfeiting her entitlement to the rights conferred under Articles 448 and 546 of the Civil Code.

Issue:

Jurisdiction and Legal Attack on Title

• Whether it was proper for the RTC and the Court of Appeals to declare the petitioner’s Certificate of Land Ownership Award (OCT No. CLOA-1748) as null and void through a collateral attack.
• Whether the timing of the issuance and registration of the Torrens title shielded it from being challenged.

Validity of the Affidavit as a Donation

• Whether Esperanza’s Affidavit—a document wherein she renounced her rights over the property—fulfilled the legal requisites for a valid donation under Article 749 of the Civil Code, specifically concerning the acceptance and formal notice requirements.
• Whether the purported donation effected by the affidavit can be sustained, or if it is null and void for lack of acceptance and proper notification.

Possession in Good Faith

• Whether the petitioner and her husband can be recognized as possessors in good faith and subsequently entitled to the rights provided under Articles 448 and 546 of the Civil Code.
• The impact of prior knowledge, or lack thereof, regarding the defects in the title on the status of good faith possession.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)