G.R. No. 159788 - Leonero vs. Spouses Barba

Petitioners – Sotero Roy Leonero, Rodolfo Lim, Isidoro A. Padilla, Jr., Amy Rose Fisma, and Norma Cabuyo – initiated a complaint for Quieting of Title and Preliminary Injunction before the RTC of Quezon City, Branch 216 (docket Q-94-20097).
The complaint sought that Transfer Certificates of Title (TCT) Nos. 59721, 59725, 59726, and 59727, issued in the name of respondents (Spouses Marcelino B. Barba and Fortuna Marcos-Barba, represented by Imelda N. Forondo) and registered by the Register of Deeds of Quezon City, be declared null and void.
Petitioners contended that these TCTs derived from Original Certificate of Title (OCT) No. 614, which, they allege, had been rendered void in a Partial Decision in Civil Case No. Q-35672.

Respondents argued that the TCTs in question were genuine and validly issued by the Register of Deeds and correctly plotted by the Land Registration Authority.
They maintained that the Partial Decision in Civil Case No. Q-35672 was inapplicable to them because they were not parties to that case.
Additionally, it was noted that petitioners, as possessors of the disputed lots, had previously been ordered by the Metropolitan Trial Court (MeTC), Branch 36, to vacate these parcels under a writ of execution issued on April 6, 1994.

On May 6, 1994, directing the parties to submit memoranda for resolution;
On July 7, 1994, denying the petitioners’ prayer for a writ of preliminary injunction and dismissing the principal action for quieting of title.

Petitioners moved for reconsideration and for leave to amend the complaint; however, by the order dated July 29, 1994, the RTC denied the motion for reconsideration and, by extension, did not act on the motion to amend.
Dissatisfied with the RTC’s order, petitioners appealed to the Court of Appeals (CA), where the appeal was effectively denied in the CA Decision dated July 31, 2002, affirming the RTC’s dismissal.
A subsequent motion for reconsideration of the CA Decision was also denied by the Resolution dated September 8, 2003.

Petitioners argued that the dismissal of their complaint for quieting of title—delivered without a trial on the merits—deprived them of the opportunity to substantiate their claims that respondents’ TCTs were null and void.
They based their claim on the supposed nullity of OCT No. 614, which they asserted should consequently vitiate the derivative TCTs.
The controversy was compounded by the fact that petitioners themselves acknowledged their status as mere possessors of the land and the existence of a prior ejectment action enforcing their eviction.

Whether the Court of Appeals erred in affirming the RTC’s dismissal of the petitioners’ claim for quieting of title without a full trial on the merits.

Whether the dismissal—based on the insufficiency of establishing a factual basis for the nullity of respondents’ TCTs—deprived petitioners of their right to a complete adjudication.
Whether petitioners’ action constituted an impermissible collateral attack on the validity of the TCTs, given that any challenge to a certificate of title must be pursued in a direct proceeding.

Whether the action for quieting of title was the appropriate judicial forum to contest the purported nullity of the TCTs.
Whether another proper remedy, such as an action for annulment of title, should have been pursued instead.