Ibot vs. Heirs of Tayco

Facts:

Baltazar Ibot v. Heirs of Francisco Tayco, G.R. No. 202950, April 06, 2015, Supreme Court Third Division, Reyes, J., writing for the Court. The petition under Rule 45 assails the Court of Appeals Decision dated November 14, 2011 and Resolution dated July 16, 2012 in CA-G.R. CV No. 00377-MIN, which reversed the Regional Trial Court of Midsayap, Cotabato, Branch 18, Judgment of March 31, 2005 in Civil Case No. 99-028.

The parties are Baltazar Ibot (petitioner), the registered owner of Lot No. 299 covered by Original Certificate of Title (OCT) No. P-62053 issued October 23, 1997, and the Heirs of Francisco Tayco (respondents), represented by Flora Tayco, Willy Tayco and Merlyn T. Bulante, who occupied the lot and sought reconveyance. Respondents alleged their predecessor-in-interest, Francisco Tayco, purchased Lot No. 299 in 1960 from Amelita Ibot and occupied it continuously and notoriously since 1964; they claimed loss of documentary proof (including the deed of sale) and reliance on possession and improvements as basis for reconveyance. They filed a complaint for reconveyance, damages and attorney’s fees on September 23, 1999.

Petitioner denied the sale, asserting that respondents’ occupation was permissive or tolerated by his predecessor-in-interest (Amelita), that Amelita later transferred her rights to him, and that he validly obtained title after complying with free-patent procedures. Petitioner produced certified documents including OCT No. P-62053, a 1998 tax declaration, his free-patent application and DENR action, a demand to vacate (May 25, 1999), and related barangay certification; he also filed an ejectment suit that was dismissed for lack of jurisdiction.

At pre-trial, the parties framed the issue as whether the registered owner’s title prevails or the occupants’ long possession (since 1964) prevails; admissions included respondents’ open occupation since 1964 and petitioner’s status as registered owner who paid taxes. The RTC rendered judgment on March 31, 2005, denying reconveyance and ordering respondents to surrender possession, reasoning that petitioner complied with registration requirements and that his title had become indefeasible. On appeal the Court of Appeals reversed on November 14, 2011, declaring the respondents legal owners and ordering reconveyance, reasoning that respondents’ long possession and improveme...(Pro-only)

Issues:

• Under Rule 45, may the Supreme Court review conflicting factual findings of the Court of Appeals and the trial court?
• Whether the respondents proved by clear and convincing evidence their right to reconveyance of Lot No. 299.
• Whether the Court of Appeals correctly applied precedents (Heirs of Dela Cruz; Naval v. CA; Aznar Brothers Realty Co. v. Aying) to find fraud, constructive trust, or to prioritize possession over petitioner’s Torrens title.
• Whether prescription and equitable laches bar the petitioner’s cl...(Pro-only)

Ruling:

• (Pro-only)

Ratio:

• (Pro-only)

Doctrine:

• (Pro-only)