Case Digest (G.R. No. L-8799)
Case Digest (G.R. No. L-8799)
Facts:
Heirs of Datu Mamalinding Magayoong, represented by Dr. Maimona Magayoong-Pangarungan with her spouse Datu Sa Marawi Rasid Pangarungan, and Dr. Anisha Magayoong-Macabato with her spouse Datu Khaliquzzaman Macabato, petitioners, vs. Heirs of Catamanan Mama, represented by Hasan Mama, respondents, G.R. No. 208586, June 22, 2016, the Supreme Court Second Division, Carpio, J., writing for the Court.The dispute concerns a small parcel in Lilod-Madaya, Marawi City described in the pleadings as a portion of Cadastral Lot No. 38 (about 510 sq. m.) that petitioners claim was sold in 1963 by Muslim Ayo to Mamalinding Magayoong by a Deed of Absolute Sale for P800.00; an Original Certificate of Title (OCT) No. P-189 was later issued in the name of Mamalinding Magayoong on 18 November 1966. Petitioners’ predecessors allegedly possessed, fenced, paid taxes on, mortgaged (circa 1981) and built houses and a clinic on the property; petitioners continued occupation after Mamalinding’s death in 1985.
Respondents (the heirs of Catamanan Mama) traced their claim to a partition judgment in Civil Case No. 1953 (Partition of Real Property, Maroki Asar Ayo Munder v. Muslim Ayo) that resulted in an Alias Writ of Execution dated 4 September 1979 affecting Lot 38-C. In 1993 respondents sent petitioners a demand letter (with the alias writ attached) to vacate and pay arrearages. Thereupon petitioners filed Civil Case No. 1073-93 (Quieting of Title) on 24 September 1993 in Branch 9, RTC, Lanao del Sur.
At pretrial the RTC terminated pre-trial on 25 November 1993. Because respondents admitted material facts in their Answer, petitioners moved for judgment on the pleadings; the trial court granted that motion in a decision dated 14 November 1994. Respondents appealed; in 1999 the Court of Appeals (CA), Manila set aside that decision and remanded for reception of evidence. Trial ensued in the RTC, parties submitted memoranda, and on 25 March 2009 the RTC (Branch 9, Marawi City) rendered judgment quieting petitioners’ title (finding strong proof of purchase, long uninterrupted possession, tax declarations and payments, mortgages, and interments on the lot) and awarded moral and exemplary damages and attorney’s fees.
Respondents appealed to the CA which, on 25 September 2012 in CA-G.R. CV No. 01867-MIN, reversed and set aside the RTC decision and dismissed the complaint for lack of cause of action. The CA held that petitioners had not shown a clear legal or equitable title and that material discrepancies between the 1963 deed (describing a 510-sq.m. parcel “covered by TCT No. T‑254”) and the OCT (describing Lot 38‑C of 503 sq. m., surveyed in 1965‑66 and covered by a free patent) prevented identification of the land; it also treated petitioners’ allegations as describing acts of ejectment rather than a cloud on title. Petitioners filed a Motion for Reconsideration which the CA denied in a Resolution dated 10 July 2013.
Petitioners invoked Rule 45 for review in the Supreme Court, assailing the CA Decision (25 September 2012) and Resolution (10 July 2013). The Court, in this Second Division decision authored by Justice Carpio and promulgated 22 June 2016, set aside the CA rulings and remanded the case to the RTC for a relocation survey to determine the identity of the property and further proceedings consistent with that determination.
Issues:
- Did the Court of Appeals err in dismissing petitioners’ complaint for lack of cause of action?
- Do petitioners possess the requisite legal or equitable title to maintain an action for quieting of title?
- Was the identity of the land sufficiently established to allow final adjudication, or is a relocation survey required?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)