Case Digest (G.R. No. 230784)
Facts:
In Heirs of Angel Yadao v. Heirs of Juan Caletina, G.R. No. 230784, decided on February 15, 2022 under the 1987 Constitution, petitioners are the heirs of Angel Yadao, Josefina Yadao and Ofelia Yadao-Naceno who trace their title to an unnotarized Contrata dated September 28, 1962 and a notarized Deed of Absolute Sale on October 15, 1962, transferring a parcel denominated Lot 1087, Cadastre 317-D (1,797 sq. m.) in Taggat Norte, Claveria, Cagayan, from the children and common-law wife of the registered owner, Juan Caletina. Respondents, heirs of Juan Caletina, filed an ownership and recovery suit on June 22, 1993 before the Regional Trial Court (Branch 12, Sanchez Mira), alleging that they remained the lawful owners and petitioners wrongfully occupied the land. Petitioners countered that they had valid title by sale and, alternatively, had acquired the property by 30-year acquisitive prescription. The RTC dismissed respondents’ claim for lack of jurisdiction, then reinstated it, aCase Digest (G.R. No. 230784)
Facts:
- Parties and Subject Matter
- Petitioners:
- Heirs of Angel Yadao (Rufina Yadao, Etherlyn Yadao-Yasaña, Ryanth Yadao, Ruth Ann Yadao-Mangibunong, Dina Joyce Yadao-Ines, Angel Yadao, Jr.)
- Heirs of Josefina Idica-Yadao (Lourdes Yadao-Apostol, Aurora Yadao)
- Heirs of Ofelia Yadao-Naceno (Teodulfo Naceno, Jr., Aileen Naceno, Irma Naceno-Agpaoa)
- Respondents: Heirs of Juan Caletina (Hospicio Caletina, Jr.; Aniceto Caletina; Florida Caletina)
- Disputed Property: Lot 1087 of Cadastre 317-D, Barangay Taggat Norte, Claveria, Cagayan; area: 1,797 sq m; covered by Original Certificate of Title No. P-479 (S).
- Antecedents and Trial Proceedings
- June 22, 1993: Respondents filed before RTC Sanchez Mira a complaint for ownership and recovery of possession against petitioners’ predecessors-in-interest, alleging succession to Lot 1087 and ouster by petitioners since 1991.
- Petitioners’ predecessors-in-interest (Josefina and Domingo Yadao) averred they bought the lot on September 28, 1962 via an unnotarized “Contrata” and on October 15, 1962 via a notarized Deed of Absolute Sale for ₱850, took delivery of the owner’s duplicate OCT, and openly possessed and leased the property continuously.
- Respondents denied any valid sale; their witnesses (Hospicio Jr. and Dolores) gave conflicting testimony, at one point admitting sale of the house for ₱300 but denying sale of the land.
- Petitioners challenged RTC jurisdiction for assessed value being below jurisdictional threshold; the RTC dismissed then reinstated the case.
- November 25, 2011 RTC Decision: Declared respondents owners by succession; found Contrata unenforceable (unnotarized) and DoAS void (seller had no title); held prescription inapplicable to registered land.
- February 29, 2016 CA Decision: Affirmed RTC; held Torrens title superior to unregistered deeds; prescription and laches do not apply to registered lands; rejected petitioners’ ownership claims; denied motion for reconsideration on December 20, 2016.
Issues:
- Did the Regional Trial Court have jurisdiction over the subject matter of the complaint?
- Did petitioners acquire ownership of the subject lot by acquisitive prescription?
- Is respondents’ action already barred by extinctive prescription?
- Is there a valid and binding contract of sale (Contrata and Deed of Absolute Sale) transferring Lot 1087 to the Yadaos?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)