Case Digest (G.R. No. L-67742)
Facts:
In Meliton Gallardo and Teresa Villanueva v. Marta Villanueva Vda. de Agana, et al. (239 Phil. 243, October 29, 1987), petitioners Meliton Gallardo and Teresa Villanueva sought to quiet title over an 83,300-sq. m. parcel in Cavinti, Laguna, originally covered by Original Certificate of Title (OCT) No. 2262 in the name of the late Justice of the Peace Pedro Villanueva. On August 10, 1937, petitioners presented a private, unnotarized deed of sale (Exhibit B), purportedly executed by Villanueva for ₱500.00. Relying on that document, OCT No. 2262 was cancelled and Transfer Certificate of Title (TCT) No. RT-6293 issued in petitioners’ names on January 4, 1944. During World War II the records burned, and a 1958 Affidavit of Reconstitution restored TCT No. RT-6293. In 1976 respondent Marta Villanueva Vda. de Agana filed an Affidavit of Adverse Claim, later withdrawing it, but refused to quitclaim. Petitioners then filed a complaint for Quieting of Title and Damages (Feb. 3, 1977) to anCase Digest (G.R. No. L-67742)
Facts:
- Land and Original Title
- Pedro Villanueva owned a parcel of land (83,300 sqm) in Cavinti, Laguna under Original Certificate of Title No. 2262 (Apr. 2, 1924).
- Petitioners Meliton Gallardo and Teresa Villanueva were his nephew and niece.
- Alleged Sale and Title Change
- An unnotarized deed of sale in Tagalog dated Aug. 10, 1937 (Exhibit B) purported to convey the land to petitioners for ₱500.
- Based on that private document, OCT No. 2262 was cancelled and Transfer Certificate of Title No. RT-6293 issued to petitioners on Jan. 4, 1944.
- Reconstitution of Title
- WWII destroyed registry records; a reconstitution affidavit by Teresa Villanueva (Dec. 2, 1958) led to the issuance of a new TCT RT-6293.
- Respondent Marta Villanueva vda. de Agana filed an adverse claim on Nov. 17, 1976; two co-heirs withdrew, but she persisted.
- Judicial Proceedings
- Petitioners’ demand for respondents to withdraw the adverse claim failed; a Deed of Conveyance and Release of Claim was partially executed Dec. 9, 1976 but no quitclaim was signed.
- Petitioners sued to quiet title on Feb. 3, 1977. Trial court (Jan. 20, 1982) nullified the 1937 deed and reconstituted TCT, reinstated OCT 2262, and awarded damages. The Intermediate Appellate Court affirmed on May 22, 1984.
Issues:
- Whether the unnotarized 1937 deed (Exhibit B) validly transferred ownership.
- Whether petitioners are guilty of laches.
- Whether petitioners acquired title by prescription.
- Whether the statute of limitations bars petitioners’ claim.
- Whether TCT No. RT-6293 is null and void.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)