G.R. No. 185746 - Tiorosio-EspiNo. vs. Hofilena-Europa

Petitioners: Heirs of Aquilino Ramos (represented by Wilbur M. Ramos, Marilou G. Ilagan, Lydia Galarrita, Benjamin Galarrita), Marilou, Benjamin, and Elyer Galarrita.
Respondents: Prosalita Galarrita Bagares and Danton Bagares, represented by Proserfina Galarrita.
The dispute centers on ownership and validity of a 3,000-square meter parcel of unregistered land known as Lot No. 12020 situated in Lanao, Alubijid, Misamis Oriental.

The late Basilia Galarrita-Naguita owned Lot No. 12020 (7,687 sqm.). She sold portions of the land to various parties including respondents and Aquilino Ramos.
Respondents alleged that on July 24, 1995 they purchased a 3,000 sqm. portion of Lot No. 12020.
Subsequently, Aquilino Ramos filed a free patent application with DENR for the entire Lot No. 12020.
Respondents opposed the application, alleging that Aquilino tampered the Deed of Sale of Unregistered Land by changing the lot number from 12019 to 12020.
PENRO denied the free patent application.

Petitioners (Marilou, Benjamin, Elyer, and Lydia) were buyers of portions of Lot No. 12020 from Aquilino Ramos.
The parties attempted barangay conciliation but failed to reach amicable settlement.
Petitioners claimed the land portion they possess and claim ownership over is not the same portion respondents claim.
Petitioners asserted Aquilino and his successors lived on and possessed the property since 1978.

The RTC declared the Deed of Sale of Unregistered Land tampered with and void.
The tax declarations and other records under Aquilino Ramos and his heirs for Lot No. 12020 were declared void.
Assessor offices were ordered to cancel tax declarations and records in favor of Aquilino Ramos’ heirs and purchasers.
Defendants were ordered to pay attorney’s fees of P20,000.

The Court of Appeals affirmed the RTC ruling on May 31, 2023.
The CA gave great weight to DENR’s findings on tampering and Aquilino Ramos’ judicial admission during barangay proceedings.
The CA held that the Deed of Sale was void and there was no transfer of ownership to petitioners.
The CA rejected petitioners’ claim of acquisitive prescription, noting possession of 26 years fallen short of 30-year requirement.
Petitioners were also ruled not buyers in good faith since the land was unregistered.

Petitioners assailed the CA decision under Rule 45.
They argued the lot number alteration did not invalidate the deed as the object was identifiable.
They presented survey plans as proof of their possession of the same property.
They claimed ownership by prescription (26 years possession).
They contended to be buyers in good faith without notice of seller’s incapacity.

Whether the CA erred in affirming RTC’s declaration nullifying the Deed of Sale due to alleged tampering.
Whether petitioners acquired ownership of the property by acquisitive prescription.
Whether petitioners are buyers in good faith entitled to ownership despite irregularities.
Whether the award of attorney’s fees to respondents was proper.