Facts:

The case, Reynaldo Baloloy and Adelina Baloloy-Hije v. Alfredo Hular, was decided by the Supreme Court of the Philippines on September 9, 2004 (G.R. No. 157767). The dispute arose from a complaint filed by respondent Alfredo Hular against the petitioners, who are the children and heirs of Iluminado Baloloy, in the Regional Trial Court of Sorsogon. The complaint, filed on May 11, 1993, sought the quieting of title of a parcel of real property located in Sitio PagAe, Biriran, Juban, Sorsogon, with an area of 287 square meters. Respondent Hular asserted that his father, Astrologo Hular, was the original owner of this land, which he alleged was wrongfully patented to Iluminado Baloloy. Hular contended that Baloloy had obtained a Free Patent over the land through fraudulent means on March 1, 1968, resulting in Original Certificate of Title (OCT) No. P-16540 being issued in Baloloy's favor.

The case traced its roots back to various transactions involving Lot No. 3347 and Lot No. 3

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Facts:

Parties and Dispute Background

• The dispute arises between the petitioners, Reynaldo Baloloy and Adelina Baloloy-Hije (and other heirs of Iluminado Baloloy), and respondent Alfredo Hular.
• Respondent Alfredo Hular initiated a complaint for quieting of title, asserting his father Astrologo Hular had acquired the disputed property and that, through continuous possession for over 60 years, he had acquired ownership by acquisitive prescription.
• Petitioners countered that the property in controversy was part of the estate of their deceased father, Iluminado Baloloy, whose title and free patent (OCT No. P-16540) covered Lot No. 3353, despite claims to the contrary.

Property Description and Chain of Title

• The property in controversy is linked to two cadastral designations:
• Lot No. 3347 of the Juban Cadastre—a parcel originally sold by Spouses Estopin (original owners) to Astrologo Hular, purportedly including a residential area measuring 287 square meters, later found to have an actual area of 1,405 square meters.
• Lot No. 3353—initially designated in the cadastral survey and later involved in a series of transactions, including a deed of absolute sale by Martiniano Balbedina to Iluminado Baloloy.
• Conflicting surveys and tax declarations emerged:
• The cadastral survey and special sketch plans indicated that the residential property constructed by various parties (including the petitioners and respondent) was actually located in Lot No. 3353 and not in Lot No. 3347.
• Tax Declaration Nos. 4790, 6841, and others played key roles in describing the nature (coconut versus residential) and boundaries of the lots.

Documentary and Testimonial Evidence

• Evidence advanced by the respondent included:
• Deeds of absolute sale executed by Victoriana Lagata in 1961 in favor of Astrologo Hular, claiming to convey the residential portion of Lot No. 3347.
• Testimonies and affidavits asserting that his family continuously occupied the land and that a document (deed of sale) evidencing Lino Estopin’s acquisition from Irene Griarte existed, despite the absence of admissible documentary proof.
• The petitioners presented evidence demonstrating:
• Their ancestor, Iluminado Baloloy, had secured a Free Patent No. 384019 over Lot No. 3353, thereby giving rise to OCT No. P-16540.
• The actual boundaries and areas of Lot Nos. 3353 and 3347 were established in official surveys and tax declarations (e.g., the Special Sketch Plan and certified plans from the Bureau of Lands).
• The fact that houses of the petitioners and other heirs were established on the land covered by the Torrens title, reinforcing their right to possession.

Proceedings in Lower Courts

• The Regional Trial Court (RTC) rendered a decision:
• Declaring the respondent as the absolute owner of a 1,405-square-meter portion of real property.
• Ordering reconveyance of title and the removal of the houses of petitioners, as well as awarding attorney’s fees and litigation expenses.
• The Court of Appeals affirmed the RTC ruling but, in the process, ignored or inadequately addressed key evidentiary and procedural issues raised by the petitioners.
• The petitioners then elevated the case on certiorari, seeking reversal of the lower court decisions.

Key Allegations and Contentions

• Respondent’s Claims:
• That his claim to the property is based on a valid deed purchase by his father and subsequent uninterrupted possession for over 60 years.
• That Petitioners’ title via the free patent (and OCT No. P-16540) is invalid for being procured by fraud.
• That alternative relief should include reconveyance of the title, vacating possession, and the awarding of damages.
• Petitioners’ Arguments:
• That the disputed property is legally part of Lot No. 3353, which was acquired by their father Iluminado Baloloy, as evidenced by the free patent and the registration of OCT No. P-16540.
• That the deed of absolute sale executed by Victoriana Lagata was for Lot No. 3347, and any later misinterpretation regarding boundaries (due to subsequent surveys) does not affect the validity of the Torrens title in Iluminado’s name.
• That the respondent failed to implead the other co-owners (his siblings and the State) who have indispensable interests in the subject property.

Issue:

Procedural and Joinder Issues

• Whether the respondent failed to implead the indispensable parties, namely his co-owners (his siblings) and the State, in the suit despite their immaterial interest in the title dispute.
• Whether the absence of such indispensable parties rendered the proceedings subsequent to the filing of the complaint, including the verdict, null and void.

Substantive Ownership and Title Issues

• Whether the respondent had a valid cause of action to nullify Free Patent No. 384019 and OCT No. P-16540, and thus claim sole ownership over the property.
• Whether the respondent’s contention of having acquired the property through acquisitive prescription is sustainable given the evidence on record.

Evidentiary Issues

• Whether the documentary evidence adduced by the respondent (including the alleged deed of sale and supporting tax declarations) is sufficient to prove his title.
• Whether the discrepancies in cadastral surveys and the inconsistent descriptions in different documents (e.g., deed translations) undermine the respondent’s case.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)