G.R. No. 211065 - Heirs of Extremadura vs. Extremadura

Parties and nature of the dispute
Petitioners were the Heirs of Jose Extremadura, represented by Elena H. Extremadura.
Respondents were Manuel Extremadura and Marlon Extremadura.
The controversy involved quieting of title, recovery of possession, rendition of accounting, and damages over a parcel of land occupied by respondents.

Jose’s purchase and Jose’s dealings with respondents
Jose was now deceased and filed Civil Case No. 2005-7552 in the Regional Trial Court of Sorsogon City, Branch 52 (RTC).
Jose claimed that he purchased three (3) parcels of agricultural land located in Sitio Ponong, Barrio Rizal, Casiguran, Sorsogon from Corazon S. Extremadura (Corazon), the widow of his uncle Alfredo H. Extremadura (Alfredo), through a Deed of Absolute Sale dated December 18, 1984.
Jose alleged that, since he resided in Manila, he placed one parcel (the subject land) in the care of Manuel.
Jose alleged that, in exchange, Manuel and his son Marlon “religiously delivered” the produce of the subject land from 1984 until 1995.
Jose alleged that respondents repeatedly refused to deliver the produce or vacate the land despite repeated demands.

Respondents’ defenses and claims of possession
Respondents averred that they had been in open, continuous, peaceful, adverse, and uninterrupted possession of the subject land for almost fifty (50) years.
Respondents asserted that the land housed their residential house.
Respondents claimed that Jose’s action was barred by prescription or laches.
Respondents claimed that delivery of portions of the produce to Jose was only in keeping with Filipino culture of sharing blessings with siblings and relatives.
Respondents argued that the deed of absolute sale Jose presented did not constitute the legal or beneficial title contemplated by Article 476 of the Civil Code.

The RTC proceedings and ruling
The RTC rendered judgment on November 23, 2011 in Civil Case No. 2005-7552.
The RTC declared Jose the rightful owner of the subject land.
The RTC directed respondents to immediately relinquish and surrender possession to Jose.
The RTC held that Jose had a better right over the land as shown by the deed of absolute sale executed in his favor, which was notarized and therefore enjoyed the presumption of regularity.
The RTC found respondents failed to substantiate their claim, including a finding that their possession was not in the concept of an owner.

Quieting of title requisites and whether Jose established title
Whether an action for quieting of title can prosper absent the kind of title and delivery findings relied upon by the CA.
Whether Jose satisfactorily established equitable title over the subject land sufficient to justify quieting of title and removal of respondents’ claim of ownership.

Delivery and transfer of ownership
Whether the CA correctly concluded that notarization alone could not result in constructive delivery and transfer of ownership because Jose was allegedly never placed in possession and control.
Whether the prima facie presumption of delivery arising from the public instrument was negated by proof that Jose did not obtain control and possession.

Concept of possession and weight of evidence of ownership
Whether respondents’ possession was in the concept of owner.
Whether Jose’s acts—receiving fruits through Manuel, allowing continued occupancy by respondents as caretakers, and paying taxes—supported a finding of possession in the concept of owner and equitable ownership.