G.R. No. 236619 - Heirs of Enano vs. San Pedro Cineplex Properties, Inc.

The petitioners, the Heirs of Manuel EAano represented by Virgilio A. Bote, filed a Complaint for Quieting of Title with Damages seeking sole ownership of a disputed parcel of land located at Barangay Landayan, San Pedro, Laguna.
The subject property was allegedly owned by Manuel EAano as evidenced by Transfer Certificate of Title (TCT) No. T-35050 and a corresponding Tax Declaration (No. 24-0007-12938).
Manuel had maintained open and continuous possession of the property since 1966 until his death in 1987, after which his heirs took over its possession.
Jennifer EAano Bote, Manuel’s daughter, authorized her husband Virgilio through a Special Power of Attorney in August 2006 to initiate the quieting title action.

In June 2006, while petitioners maintained possession, respondent San Pedro Cineplex Properties, Inc. initiated a Complaint for Forcible Entry alleging registered ownership based on TCT Nos. T-309608, T-309609, and T-309610.
Upon verification, petitioners discovered that the respondent’s titles were allegedly fictitious, thereby casting a cloud over Manuel’s title.
The RTC of San Pedro, Laguna (Branch 93) initially ruled in favor of petitioners by declaring the respondent in default and upholding petitioners’ title based on the chain of possession and documentary evidence, including the original sale dated May 13, 1965.

Petitioners contended that Manuel acquired the subject property through an Absolute Deed of Sale from the Spouses Gliceria Kasubuan, further evidenced by TCT No. T-35050 and continuous possession since 1965.
During the trial, petitioners relied on evidence of longstanding possession, tax payments, and the absence of any reconstitution petition regarding the clouded titles.
Conversely, respondent presented a detailed chain of title tracing the property’s history from Gliceria’s Original Certificate of Title (OCT No. 0-217) through subsequent transfers from the Spouses Sibulo, DoAa Crisanta Investment, to La Paz Housing, which eventually sold the property to the respondent in 1994.
Respondent also argued that the title allegedly pointed out by petitioners, TCT No. T-35050, actually covered a much smaller parcel (219 square meters) and was registered under another name, thereby undermining petitioners’ claim.

The RTC rendered a decision on June 20, 2014, declaring that petitioners held superior rights over the subject property and nullifying respondent’s certificates.
On appeal, the Court of Appeals reversed the RTC decision on August 15, 2017, holding that petitioners failed to prove by a preponderance of evidence that they had a legal or equitable title.
Following a denied Motion for Reconsideration by the CA in its January 4, 2018 Resolution, the case eventually reached the Supreme Court.

The dispute also involved a parallel Complaint for Forcible Entry where the Municipal Trial Court (MTC) found respondent to be in constructive possession of the property, a ruling later reinstated by the CA.
Evidentiary issues were highlighted in the trial, particularly regarding the weight of documentary evidence over testimonial evidence and the conflicting chain of transactions leading to the respondent’s possession.
Petitioners further alleged that the respondent’s titles were the product of a non-existent reconstitution proceeding, rendering them fictitious and void.

Whether petitioners proved by a preponderance of evidence that they have a legal (registered) or equitable (beneficial) title over the subject property.
Whether TCT No. T-35050 and the accompanying Tax Declaration were adequate to establish ownership given the conflicting evidence of title.

Whether the chain of transactions from the original mother title (OCT No. 0-217) to the respondent’s TCT Nos. T-309608, T-309609, and T-309610 sufficiently established a valid title free from any cloud.
Whether the alleged reconstitution of the La Paz Housing titles, which did not take place, invalidates respondent’s claim.

The issue of whether Virgilio A. Bote, as a representative of the heirs (through a Special Power of Attorney), had the requisite authority to institute the action.
The necessity to include or implead co-owners in the suit, especially in cases of co-ownership disputes.

Whether the documentary evidence presented by respondent regarding the chain of title should prevail over petitioners’ affidavit and tax records.
The evidentiary standard required under quieting title actions, particularly in proving that any alleged cloud is indeed invalid or void.

Whether the alleged fraudulent nature of the sale between respondent and La Paz Housing suffices to void respondent’s title.
Whether the issue regarding the actual area and registration details of TCT No. T-35050 undermines petitioners’ claim.