G.R. No. L-36824 - People vs. Guillermo

On October 14, 1957, Julian Cuizon executed a Deed of Extrajudicial Settlement and Sale over Lot No. 4539 in Ibo, Municipality of Opon (now Lapu-Lapu City), conveying the property to the Civil Aeronautics Administration (CAA), predecessor of MCIAA.
MCIAA and its predecessors (CAA, Bureau of Air Transportation, Air Transportation Office) maintained material, continuous, uninterrupted, and adverse possession; the lot was later conveyed to MCIAA by virtue of Republic Act No. 6958.

In 1980, respondents caused the judicial reconstitution of Original Certificate of Title No. RO-2431 for Lot No. 4539 in the names of the heirs of Gavina Ijordan and other co-heirs (Julian, Francisca, Damasina, Marciana, Pastor, Angelina, Mansueto, Bonifacia, Basilio, Moises, Florencio Cuizon).
They asserted they never sold nor authorized Julian to sell their shares and refused to surrender the owner’s copy of OCT No. RO-2431.

MCIAA filed a complaint in the RTC (Branch 53, Lapu-Lapu City) to cancel respondents’ Torrens title, alleging the 1957 Deed and Tax Declaration No. 00387 conferred ownership and obligation to surrender the OCT. MCIAA presented one witness, its legal assistant.
Respondents moved for a Demurrer to Evidence (Feb. 3, 1997), contending the photocopied Deed was inadmissible (Rule 130, Sec. 3), unenforceable without co-heirs’ consent (Art. 1317, Civil Code), and the tax declaration derived from an unenforceable sale.
RTC Order (Sept. 2, 1997): granted the demurrer with qualification—dismissed MCIAA’s complaint as to respondents’ shares but declared MCIAA owner of Julian’s 1/22 undivided share. The court noted Cadastral Case No. 20 and Decree No. 531167 issued in 1930, lack of proof of improvements or uninterrupted possession, and the indefeasibility of Torrens title. Reconsideration was denied (Mar. 6, 1998).
The Court of Appeals affirmed both RTC orders (Feb. 22, 2006) and denied MCIAA’s motion for reconsideration (June 15, 2006). MCIAA then filed the present petition for review on certiorari.

Whether the 1957 Deed validly conveyed the entire Lot No. 4539 to MCIAA or only Julian Cuizon’s undivided share.
Whether respondents’ prolonged inaction and alleged awareness constitute implied ratification of the sale or estoppel by laches.
Whether MCIAA acquired ownership of respondents’ shares through adverse possession or acquisitive prescription under the Torrens system.