Case Digest (G.R. No. 137305)
Facts:
The case involves petitioners Quirino Mateo and Matias Mateo, sons of Simeona Manuel-Mateo and Claro Mateo, against respondents Dorotea Diaz, Reynaldo Diaz, Remedios Diaz, Adoracion Diaz, Norberto Diaz, Yolanda Cruz, Oscar Cruz, Ester Cruz, Nenita Cruz, Primo Policarpio, Gavino Policarpio, Florentina Policarpio, Mauro Policarpio, and Miguel Policarpio. The dispute centers on an 11-hectare riceland located in Bulak, Sta. Maria, Bulacan, covered by Original Certificate of Title (OCT) No. 206 issued on October 21, 1910, in the name of Claro Mateo. Claro died in 1932 and Simeona died in 1948. Prior to their deaths, the property was inherited by their children from two marriages: Cornelia Mateo-Diaz and Felisa Mateo-Policarpio from the first marriage, and Quirino and Matias Mateo from the second.
In June 1951, the children executed a document dividing among themselves three parcels of land inherited from their parents, but it is unclear if the disputed land was included. In 1979, Q
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Case Digest (G.R. No. 137305)
Facts:
- Family Background and Parties Involved
- Canuto Mateo and Simeona Manuel-Mateo were married and had two daughters: Cornelia Mateo and Felisa Mateo.
- Cornelia Mateo married Ulpiano Diaz and had children: Dorotea, Reynaldo, Remedios, Adoracion, and Norberto Diaz.
- Felisa Mateo married Cirilo Policarpio and had children: Primo, Gavino, Florentina, Mauro, and Miguel Policarpio.
- Cornelia’s grandchildren include Yolanda, Oscar, Ester, and Nenita Cruz.
- Marital Changes and Birth of Petitioners
- Canuto Mateo died in 1898.
- Simeona Manuel-Mateo remarried Claro Mateo (a first cousin of Canuto).
- Simeona and Claro Mateo had two sons: Quirino Mateo and Matias Mateo, the petitioners.
- Subject Property
- The disputed 11-hectare riceland located at Bulak, Sta. Maria, Bulacan was covered by Original Certificate of Title (OCT) No. 206 issued on October 21, 1910, in the name of Claro Mateo, married to Simeona Manuel.
- Claro Mateo died on September 8, 1932; Simeona Manuel-Mateo died on October 18, 1948.
- Land Partition and Possession
- On June 12, 1951, Simeona’s children from both marriages executed a document dividing three parcels of inherited land in Bulak, Sta. Maria, Bulacan. It was unclear if these included the land covered by OCT No. 206.
- The parties peacefully and continuously possessed their portion of land following the partition.
- On February 15, 1979, Quirino and Matias Mateo executed an extra-judicial partition deed of the 11-hectare riceland covered by OCT No. 206, excluding their half-sisters Cornelia and Felisa. This deed was published in a newspaper, alerting other family members.
- Legal Actions Arising from Partition
- In 1981, several children and grandchildren of Cornelia and Felisa filed a complaint for nullity of the extra-judicial partition and damages against Quirino and Matias Mateo in the Court of First Instance (later Regional Trial Court) of Bulacan, docketed as Civil Case No. SM-975.
- A criminal case charging Quirino and Matias with falsification of public documents was filed in San Carlos City, Pangasinan.
- In 1984, the RTC declared the extra-judicial partition void. Records noted that the court in Pangasinan convicted the Mateo brothers for falsification.
- It was not shown whether the Mateo brothers appealed these decisions.
- The Present Suit
- On April 1, 1987, Quirino and Matias Mateo filed a declaratory relief suit (Civil Case No. 165-SM-87) against members of the Diaz, Cruz, and Policarpio families, seeking ownership and possession of the disputed land.
- Various defendants moved for the dismissal of the suit on grounds including lack of barangay mediation under P.D. 1508, prior judgment, and absence of compromise efforts among family members.
- Some defendants were dismissed from the case.
- Quirino and Matias amended their complaint in 1988 to conform evidentiary facts with their cause of action.
- The defense, through amended answer with compulsory counterclaim, raised laches, prescription, the existence of several conveyances of parts of the land, adverse possession by third parties since 1910, and asserted the property was never exclusively owned by Claro Mateo.
- The defendants claimed the original land covered by OCT No. 206 should be canceled and new titles issued to those occupying the land.
Issues:
- Whether prescription and the equitable doctrine of laches apply against the petitioners’ ownership of registered land covered by OCT No. 206 despite the Land Registration Act’s prohibition on acquisition of title by prescription or adverse possession against a registered owner.
- Whether the Court of Appeals erred in awarding attorney’s fees to the respondents.
- Whether the Court of Appeals erred in ordering the cancellation of OCT No. 206 and issuance of new titles to occupants.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)