Case Digest (A.M. NO. P-04-1771) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
On September 9, 1999, Spouses Delfin and Maria Tappa (petitioners), registered owners of a 21,879-sqm parcel designated as Lot No. 3341, Pls-793 in Kongcong, Cabbo, Peñablanca, Cagayan, filed a Complaint for Quieting of Title, Recovery of Possession, and Damages against Heirs of Jose Bacud, Henry Calabazaron, and Vicente Malupeng (respondents). Petitioners asserted that they held Original Certificate of Title (OCT) No. P-69103 issued on September 18, 1992 by virtue of Free Patent No. 021519-92-3194, and that both Delfin and his predecessor Lorenzo Tappa had been in open, continuous, notorious, and exclusive possession since time immemorial. Respondents contended that the property originally belonged to Genaro Tappa and passed by law to his children Lorenzo and Irene; after Irene’s death her share devolved to her heirs, including Bacud. Pursuant to a 1963 joint affidavit signed by Delfin, his sisters, and mother, respondents asserted Irene’s co-ownership. Calabazaron and Malupeng Case Digest (A.M. NO. P-04-1771) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Subject Property
- Spouses Delfin and Maria Tappa filed on September 9, 1999 a complaint for Quieting of Title, Recovery of Possession, and Damages over Lot No. 3341, Pls-793 (21,879 sq m) in Kongcong, Cabbo, Peñablanca, Cagayan, asserting registration under OCT No. P-69103 via Free Patent No. 021519-92-3194 (1992) and continuous possession since time immemorial.
- Respondents José Bacud, Henry Calabazaron, and Vicente Malupeng claimed co-ownership through Genaro Tappa’s heirs: Lorenzo and Irene; presented a 1963 affidavit by Lorenzo’s children and Modesta Angoluan; alleged valid deeds of sale (1970, 1971) to Calabazaron (2,520 sq m) and Malupeng (210 sq m), and succession to Bacud (1,690 sq m); admitted paying taxes and occupying their portions since the 1960s.
- RTC Proceedings and Decision
- RTC of Tuguegarao City (Branch 5) ruled in favor of Spouses Tappa, finding clear title unassailed, declared respondents must convey their portions, and dismissed prescription and cloud assertions.
- It held the 1963 affidavit insufficient against a registered Torrens title and found no evidence of force or intimidation that would invalidate it.
- CA Proceedings and Decision
- Court of Appeals reversed (February 19, 2009), dismissing Spouses Tappa’s complaint, and denied their motion for reconsideration (April 30, 2009).
- CA found respondents’ adverse possession since 1963 ripened into ownership by acquisitive prescription (30 years), held the free patent on private land void, declared Spouses Tappa lacked title or interest under Arts. 476–477 CC, and ruled the alleged fraud on the 1963 affidavit unproven.
Issues:
- Did the CA err in dismissing Spouses Tappa’s complaint for quieting of title?
- Did the CA err in holding that Spouses Tappa’s certificate of title may be collaterally attacked?
- Did the CA err in finding that respondents acquired ownership through acquisitive prescription?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)