Case Digest (G.R. No. 233055)
Case Digest (G.R. No. 233055)
Facts:
Heirs of Pedro Bernardo and Pacita Ronquillo, represented by Belen B. Ortiz, et al. v. Spouses Guadalupe M. Gamboa and Trinidad Caballero, G.R. No. 233055, August 19, 2020, First Division, Reyes, J., writing for the Court.The dispute concerns two adjacent parcels in Sitio Bical‑Bical, Diwalaan, General Tinio, Nueva Ecija: Lot 1323 (later reduced to Lot 1323‑B) and Lot 1324. The petitioners are the heirs of Pedro and Pacita Ronquillo (hereafter “petitioners”), who trace title to Lot 1323 from OCT No. P‑2980; a prior CA ruling in 1978 ordered reconveyance of 8,161.705 sq.m. from the Ronquillos to the Paredes, producing Lot 1323‑B (TCT No. NT‑109773). When the petitioners inherited, title was under TCT No. NT‑308292.
Respondents Spouses Guadalupe M. Gamboa and Trinidad Caballero acquired Lot 1324 by a notarized Kasulatan ng Bilihang Tuluyan dated May 15, 1978, claiming continuous occupation by predecessors since 1925; they exercised acts of ownership (planting mango trees, structures) and paid taxes. In November 2003 a relocation survey of Lot 1323‑B revealed that 14,749 sq.m. apparently in respondents’ physical possession had been included in petitioners’ title.
Respondents filed a Complaint for Cancellation and/or Reconveyance with Damages (Dec. 23, 2003) praying for segregation of the 14,749 sq.m. from petitioners’ TCT and issuance of a new title in their names. Petitioners answered with a counterclaim, asserting res judicata, prescription and laches, and sought damages. The parties stipulated at pre‑trial that respondents were in actual physical possession of the disputed 14,749 sq.m.; trial proceeded.
The Regional Trial Court (RTC), Branch 34, Gapan City, rendered judgment on February 9, 2015 in favor of respondents, ordering petitioners to subdivide Lot 1323‑B, segregate 14,749 sq.m., and have that portion titled in respondents’ names, and to cause partial cancellation of TCT No. NT‑308292. Petitioners appealed to the Court of Appeals (CA) in CA‑G.R. CV No. 104636; the CA denied the appeal in a Decision dated January 31, 2017 and denied reconsideration in a Resolution dated July 18, 2017. Petitioners then filed a Petition for Review on Certiorari under Rule 45 in this Court, which denied the Petition for lack of merit and affirmed the CA decision.
Issues:
- Is the action for reconveyance filed by respondents a collateral attack upon petitioners’ Torrens title?
- Could respondents properly seek subdivision/segregation and titling of the 14,749 sq.m. portion through their reconveyance action?
- Did respondents prove by preponderance of evidence the identity of Lot 1324, their ownership/possession, and fraud by petitioners’ predecessor-in-interest in having the 14,749 sq.m. included in OCT No. P‑2980?
- Are respondents the real parties in interest authorized to bring this action?
- Is the action barred by prescription or laches?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)