Case Digest (G.R. No. 236619)
Facts:
Heirs of Manuel Enano, represented by Virgilio A. Bote, vs. San Pedro Cineplex Properties, Inc., G.R. No. 236619, April 06, 2022, Supreme Court Second Division, Hernando, J., writing for the Court. Petitioners are the heirs of Manuel H. Enano, represented by Virgilio A. Bote under a Special Power of Attorney executed by his wife Jennifer Enano Bote; respondent is San Pedro Cineplex Properties, Inc.In August 2006 petitioners (through Virgilio) filed a Complaint for Quieting of Title with Damages to remove what they alleged was a cloud on their title to a 74,847 sq. m. parcel in Barangay Landayan, San Pedro, Laguna. Petitioners relied on Transfer Certificate of Title No. T-35050 (registered in Manuel’s name) and long possession since 1966. Respondent had previously filed a Complaint for Forcible Entry claiming ownership by virtue of TCT Nos. T-309608, T-309609 and T-309610; petitioners later discovered after checking the Register of Deeds that those TCTs purportedly originated from unnotarized/undated instruments and contended they were fictitious.
Procedurally, respondent initially moved to dismiss in the RTC of San Pedro; the RTC denied dismissal, declared respondent in default, and the CA affirmed the default. This Court (in an earlier petition) denied review but on reconsideration remanded because respondent’s answer had been filed before the default declaration; the case returned to the RTC. Parallelly, in the forcible-entry ejectment proceedings the MTC of San Pedro found respondent in constructive possession and ordered petitioners to vacate; the RTC reversed but the CA reinstated the MTC decision, and this Court later remanded to the MTC to determine which certificates actually covered the land and to award possession.
Following remand the MTC, after a survey confirming the competing titles covered the same lot, sustained its order directing petitioners to vacate. The RTC then proceeded with the quieting case: parties stipulated to certain facts (SEC registration of respondent, existence of the ejectment decision, and existence of the certificates of title) and trial on the merits followed. Petitioners testified to purchase by Manuel in May 1965, issuance of TCT No. T-35050, continuous possession and tax payments; they argued respondent’s titles trace to La Paz Housing’s allegedly reconstituted and therefore fictitious TCTs. Respondent presented a detailed documentary chain of title from OCT No. 0-217 (Gliceria) through successive transfers to respondent and argued petitioners’ TCT T-35050 was a cancelled title covering a different 219-sq. m. lot in Calamba.
On June 20, 2014 the RTC ruled for petitioners, held they had the better right, declared respondent’s TCTs null and void, and awarded attorney’s fees. Respondent appealed; in an August 15, 2017 Decision the Court of Appeals reversed and dismissed the Complaint for lack...(Subscriber-Only)
Issues:
- Did Virgilio A. Bote have legal personality to institute the quieting action on behalf of Manuel’s heirs?
- Did petitioners prove by preponderance of evidence that they have a legal or equitable title to the subject property as required under Articles 476 and 477 of the Civil Code?
- Did petitioners sufficiently prove that respondent’s certificates of title (T-309608, T-309609, T-309610) were fictitious or void so as to constitute a cloud on petitioners’ title?
- If the quieting action fails, are the other issu...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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