G.R. No. 169890 - Esguerra vs. Trinidad

The dispute involves two parcels of land located in Camalig, Meycauayan, Bulacan.
Petitioners are grandchildren of Felipe Esguerra and Praxedes de Vera (the Esguerra spouses), namely Feliciano, Canuto, Justa, Angel, Fidela, Clara, and Pedro Esguerra.
Respondents include Virginia Trinidad, Primitiva Trinidad, and the Register of Deeds of Meycauayan, Bulacan.

A 35,284-square meter parcel (Tax Declaration No. 10374): Half (17,642 square meters) was sold to the petitioners.
A 23,989-square meter parcel (Tax Declaration No. 12080): A major portion was sold to the petitioners, while 500 square meters was sold to other grandchildren, the Trinidad brothers.

The deed of sale in favor of petitioners was executed on August 11, 1937.
The corresponding deed of sale in favor of the Trinidad brothers was executed on August 17, 1937.
Both deeds were executed before notary public Maximo AbaAo.

Further conveyance arose when Eulalio Trinidad sold his share to his daughters (the respondents) through a notarized Kasulatan ng Bilihang Tuluyan ng Lupa dated October 13, 1965.
Cadastral Survey and Title Assignment:

A portion of the land, 1,693 square meters, was assigned as Lot No. 3593 during a late 1960s cadastral survey.
On application, the then Court of First Instance (CFI) of Bulacan awarded Lot No. 3593 to the respondents by its Decision dated February 20, 1967, in Land Registration Case No. N-323-V.
Pursuant to the CFI decision, the Land Registration Commission (now LRA) issued Decree No. N-114039, leading to the issuance of OCT No. 0-3631.

Petitioners sold a portion of about 5,000 square meters (from the 23,989-square meter parcel) to the Trinidad spouses under a notarized Bilihan ng Lupa dated November 10, 1958.
A discrepancy was later noted during the cadastral survey, where the area assigned as Lot No. 3591 measured 6,268 square meters instead of the stated 5,000 square meters.
The CFI, by its Decision dated August 21, 1972 in Land Registration Case No. N-335-V, awarded Lot No. 3591 to Eulalio Trinidad, and the corresponding OCT No. 0-6498 was subsequently issued.
Following the death of the Trinidad spouses, Lot No. 3591 was transmitted to the respondents by succession.

Petitioners alleged that the issuance of the two OCTs (OCT No. 0-3631 and OCT No. 0-6498) was procured through fraud or misrepresentation.
On August 29, 1994, petitioners filed two separate complaints before the RTC of Malolos, Bulacan, seeking the cancellation of these OCTs.
The cases were consolidated, tried by Branch 79 of the RTC, and eventually dismissed by a Joint Decision on May 15, 1997.
The Court of Appeals affirmed the dismissal with a Decision dated February 28, 2005 and a subsequent Resolution on October 3, 2005.
Petitioners attempted to address procedural lapses by submitting a Compliance, including a Verification and Sworn Certification on Non-Forum Shopping, though it was filed later (January 16, 2006).
The petitioners argued that:

Whether the respondents’ acquisition, registration, and issuance of the OCTs were procured by fraud or misrepresentation.

Whether the lower courts erred in their interpretation and application of Article 1542 of the Civil Code, particularly in the context of the discrepancy between the stated and actual land areas.

Whether the petitioners’ failure to comply with procedural requirements (such as the verification and certification on non-forum shopping as well as the attachment of essential portions of the case record) warrants the dismissal of the petition.

Whether the evidence or lack thereof supports the petitioners’ contention of fraud in respondents’ acquisition and registration of the land titles.