Facts:

In the case of Erlinda S. Igot vs. Pio Valenzona et al., G.R. No. 230687 was decided by the Supreme Court on December 5, 2018. The controversy centered around ownership and possession of a parcel of land known as Cadastral Lot No. 286 located in Taft Street, Ipil II, Poblacion, Palompon, Leyte. The respondents, Pio Valenzona, Francisco Valenzona Nuaez, Katherine Valenzona Ramirez, and spouses Arturo and Aida Valenzona, claimed ownership rights based on inheritance from their predecessors, the spouses Julian and Sotera Valenzona. They contended that their family had possessed the property for over 50 years.

Petitioner Erlinda S. Igot, through her mother, Elena Santome, alleged ownership, claiming that her father Gorgonio Santome purchased the property from Julian Valenzona in 1929. During the proceedings, it was noted that in 1998, Elena filed a recovery of ownership case against Agapito Valenzona, one of Julian's heirs, but this case (Civil Case No. 418) was adjudicated in

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Facts:

Parties and Representation

• Petitioner: Erlinda S. Igot, represented by her interests in the subject property.
• Respondents:
• Pio Valenzona;
• Francisco Valenzona;
• Katherine Valenzona Ramirez; and
• Spouses Arturo and Aida Valenzona.
• Representation in certain proceedings was by Arturo Valenzona, acting through powers of attorney.

Background and Subject Property

• The dispute centers on Cadastral Lot No. 286, located at Taft Street, Ipil II, Poblacion, Palompon, Leyte.
• Key elements include issues on tax declarations, the execution of a resurvey plan, and the demolition of an ancestral house.
• Ownership was historically divided among heirs, with questions raised as to possession in the concept of an owner.

Factual History and Procedural Developments

• Early Litigation (2008 and prior)
• In October 2008, respondents filed a complaint for recovery of possession, ownership, quieting of title, nullity of tax declarations, and a resurvey plan against petitioner and Elena Santome.
• Respondents alleged that their predecessors-in-interest, the Spouses Valenzona, had possessed the subject property for over 50 years.
• The 1998 Complaint and MTC Proceedings
• In 1998, Elena Santome, petitioner’s mother, filed a separate complaint before the Municipal Trial Court (MTC) seeking recovery of ownership and possession with damages against Agapito Valenzona, based on her claim that her father, Gorgonio Santome, acquired the property from Julian in 1929.
• The MTC found that the transfer of the property to Gorgonio, evidenced by a Transferor’s Affidavit and tax declarations, was legal despite later proceedings.
• The MTC held that the transfer of the tax declaration from Gorgonio’s name to Julian’s in 1974 was illegal, noting that Agapito Valenzona, who caused this transfer, could not invoke good faith in his capacity as Julian’s successor-in-interest.
• As a result, the MTC declared Elena (and by extension, petitioner through subsequent dealings) to be the owner, while setting aside the tax declaration in the name of Erlinda S. Igot.
• Subsequent Litigations and Transactions
• The decision in Civil Case No. 418 by the MTC (February 29, 2000) declared Elena as the owner of the subject property and ordered Agapito to vacate it, with awards for damages, attorney’s fees, and costs.
• Elena, following the 2000 decision, caused the issuance of a new tax declaration and a resurvey plan in her own name in 2004, which also involved demolishing aspects of Julian’s ancestral home.
• Petitioner and Elena later contended that ownership of the property was derived from their father Gorgonio, and on October 15, 2009, Elena sold the subject property to petitioner and her husband.
• Barangay proceedings were also initiated when respondents demanded that petitioner and Elena provide time for relocation, leading to further litigation.
• Trial Court and Appellate Decisions
• The MTC Decision (October 22, 2012) annulled Tax Declaration No. 02-31007-00107 registered in the name of Erlinda S. Igot and divided ownership: 4/5 in favor of the respondents and 1/5 for the petitioner.
• Petitioner’s Motion for Reconsideration before the MTC was denied.
• The Regional Trial Court (RTC), in its January 29, 2014 decision, reversed the MTC ruling by emphasizing that Julian had transferred the property to Gorgonio in 1929, thereby granting petitioner and Elena full and exclusive ownership of the entire property.
• The RTC ordered the respondents to vacate the premises, remove their improvements, and pay reasonable rent from February 2003, along with awarding attorney’s fees and litigation costs.
• The Court of Appeals (CA) on November 2, 2016, reversed the RTC decision and reinstated the MTC decision, noting issues on res judicata and the identity of parties.
• Petition for Review on Certiorari
• Petitioner elevated the case to the Supreme Court via a Petition for Review on Certiorari, assailing the CA’s rulings.
• The issues raised included claims of a fraudulent transfer in 1974, whether possession was in the concept of an owner, whether the respondents were real parties-in-interest, and whether acquisitive prescription or laches applied to bar petitioner’s recovery action.

Issue:

• Whether or not the fraudulent transfer of the subject property in 1974—from Gorgonio Santome to Julian Valenzona, effected by Agapito Valenzona—would benefit the other heirs of Julian.

• Whether or not the respondents’ occupation and possession of the subject property were in the concept of an owner.

• Whether or not the respondents are real parties-in-interest in the present case, particularly given that they were not all impleaded in Civil Case No. 418.

• Whether or not acquisitive prescription operates in favor of the respondents, considering the duration and nature of their possession.

• Whether or not petitioner’s action to recover the subject property is barred by prescription.

• Whether or not petitioner is guilty of laches in relation to the delay or conduct in asserting her title.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)