Case Digest (G.R. No. 175760)
Facts:
In Gatmaytan v. Misibis Land, Inc. (G.R. No. 222166, June 10, 2020), petitioners Mercedes S. Gatmaytan and Erlinda V. Valdellon purchased on December 9, 1991 a 6.4868-hectare parcel in Misibis, Cagraray Island, Albay, from Spouses Oscar and Cidra Garcia under a Deed of Absolute Sale (1991 DOAS) annotated on Transfer Certificate of Title (TCT) No. T-77703 but not transferred due to lack of DAR clearance. In 2010, they discovered that Misibis Land, Inc. (MLI) had consolidated and subdivided the lot under new titles after two intervening sales: a February 21, 1996 DOAS from the Garcias to DAA Realty Corporation, resulting in TCT No. T-97059, and an April 21, 2005 DOAS from DAA Realty to MLI, resulting in TCT No. T-138212. Petitioners promptly annotated an Affidavit of Adverse Claim in September 2010 and filed on December 10, 2014 a multi-count complaint before the RTC of Tabaco City seeking: (1) declaration of ownership and nullity of the 1996 and 2005 DOAS; (2) quieting of title;Case Digest (G.R. No. 175760)
Facts:
- Early Transactions and Registration
- December 9, 1991 – Petitioners Mercedes Gatmaytan and Erlinda Valdellon purchase a 6.4868-ha parcel (TCT No. T-77703) from Spouses Oscar and Cidra Garcia; they pay documentary and capital gains taxes.
- April 6, 1992 – Petitioners register and annotate their Deed of Absolute Sale (1991 DOAS) on TCT No. T-77703 but cannot obtain a new title for lack of DAR clearance.
- Subsequent Transfers and Discovery
- February 21, 1996 – Spouses Garcia execute a 1996 DOAS in favor of DAA Realty Corporation; TCT No. T-97059 is issued on February 22, 1996.
- April 21, 2005 – DAA Realty sells to Misibis Land, Inc. (MLI); TCT No. T-138212 is issued.
- 2010 – Petitioners resume transfer efforts; discover the lot consolidated and subdivided under multiple new titles, TCT No. T-77703 cancelled, and file an Affidavit of Adverse Claim (September 1, 2010).
- RTC Proceedings (Civil Case No. T-2820)
- December 10, 2014 – Petitioners file complaint against Spouses Garcia, DAA Realty, MLI, and Philippine National Bank for:
- Declaration of ownership and nullity of the 1996 and 2005 DOAS;
- Cancellation of TCT Nos. T-97059 and T-138212;
- Quieting of title;
- Accounting of profits;
- Moral and exemplary damages; attorney’s fees.
- MLI raises as defenses: innocent purchaser for value; prescription (10 years from 1996 issuance); lack of correct docket fees.
- October 22, 2015 – RTC dismisses complaint for prescription and failure to pay correct fees.
- December 28, 2015 – RTC denies petitioners’ motion for reconsideration.
- Supreme Court Proceedings
- January 2016 – Petitioners receive RTC orders; move for extension to file Rule 45 petition.
- February 24, 2016 – Petition for review on certiorari filed.
- April 18, 2016 – SC Second Division denies petition for form defects.
- August 22, 2016 – SC en banc grants reconsideration; petition reinstated; MLI comments; petitioners reply.
Issues:
- Whether petitioners’ complaint should proceed to trial on the merits.
- Whether petitioners’ causes of action are already barred by prescription.
- Whether petitioners’ alleged failure to pay correct docket fees is fatal.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)