G.R. No. 174004 - Cagatao vs. Almonte

The case originated from an action for annulment of deeds of sale, cancellation of title, and damages filed by petitioner Virgilio G. Cagatao on April 18, 1996.
The dispute encompasses a complex history of property transactions involving several parties with competing claims.

On February 16, 1949, a homestead patent over the disputed property (Lot No. 5598, Pls-67) was issued in favor of Juan Gatchalian.
Cagatao alleged that sometime in the 1940s, Gatchalian sold the lot to Delfin Manzulin in exchange for one carabao, based on a barter agreement that was later lost during World War II.
In 1990, Manzulin purportedly executed a private written document in the Ilocano dialect transferring ownership to his son-in-law, Cagatao, who subsequently occupied and cultivated the land.

The respondents, comprising Guillermo Almonte, Arthur Aguilar, the Spouses Ernesto and Avelina Fernandez, and the Fernandez Siblings (Marvin John, Marson, and Marjun Fernandez), presented an alternate chain of transactions.
On April 3, 1993, the Spouses Fernandez allegedly purchased the property from Almonte and Aguilar, who each possessed a tax declaration covering the lot.
To protect their interest, the Spouses Fernandez acquired the property again on January 17, 1996 from Emmaculada Carlos, who was believed to be the owner by virtue of Transfer Certificate of Title (TCT) No. T-12159-A—a reconstituted title in her name.
Subsequently, a deed of sale dated January 22, 1996 was executed in favor of the Fernandez Siblings, resulting in the issuance of TCT No. T-249437 under their names.

Cagatao questioned the validity of the deed of sale transactions, particularly the sale by Carlos, highlighting irregularities such as the simultaneous purchase from two different vendors.
He insisted that the deed transferring ownership to the Fernandez Siblings was simulated, as one of the respondents admitted that neither she nor her husband ever signed the document.
The Regional Trial Court (RTC), in its June 22, 2001 decision, ruled against Cagatao by holding that the transfers from Gatchalian to Manzulin and from Manzulin to Cagatao were invalid under Commonwealth Act No. 141, while upholding the validity of the sale between Spouses Fernandez and Carlos.
The Court of Appeals (CA) modified the RTC decision on July 29, 2005, and later reversed part of its ruling in an Amended Decision on March 9, 2006, ultimately sustaining the validity of Carlos’s title and respecting Cagatao’s possession due to the principle that only the true owner could challenge his claim of possession.

During the pendency of the case, the RTC issued a writ of preliminary injunction to protect Cagatao’s possession of the land.
The RTC’s ruling dismissed Cagatao’s claim to ownership while nullifying certain transfers—specifically, the transfer to the Fernandez Siblings.
The CA’s subsequent decisions, including an Amended Decision and a later Resolution denying further reconsideration, left Cagatao in possession pending an action by any person with a superior right.

Whether or not the Court of Appeals erred in declining to declare the reconstituted TCT No. 12159-A in the name of Emmaculada Carlos as void.
Whether or not the Court of Appeals erred in not ruling that the homestead title holder Juan Gatchalian—and by extension the petitioner as his successor-in-interest—are the true owners of the subject property.
Whether or not the Court of Appeals erred in amending the dispositive portion of the RTC’s original decision by deleting its ruling that the deed of sale between Emmaculada Carlos and the Spouses Fernandez was void.