Title
Phil-Ville Development and Housing Corp. vs. Bonifacio
Case
G.R. No. 167391
Decision Date
Jun 8, 2011
Phil-Ville contested heirs' claim over land, asserting invalid title derived from non-existent OCT. SC upheld Phil-Ville's ownership, nullifying heirs' title due to jurisdictional and validity issues.

Case Digest (G.R. No. 167391)

Facts:

  • Original titles and subdivisions
    • OCT No. 994 was registered on May 3, 1917 in the name of Isabel Gil de Sola as judicial administratrix of the Maysilo Estate (Original Land Registration Case No. 4429).
    • Portions of Lot 23-A of the Maysilo Estate were subdivided under subdivision plan Psd-2731 into Lots 1-G, 1-H, etc., covered by TCT No. T-148220.
    • Phil-Ville Development and Housing Corporation acquired Lots 1-G-1, 1-G-2 and 1-G-3 (aggregate area: 8,694 m²) by purchase from N. Dela Merced and Sons, Inc. on July 24, 1984, and these are now covered by TCT Nos. 270921, 270922 and 270923.
  • Partition proceedings involving OCT No. 994
    • In 1961, alleged heirs of Maria de la Concepcion Vidal filed Land Registration Case No. 4557 for substitution on OCT No. 994; the CFI granted substitution on May 25, 1962.
    • Petition for partition of OCT Nos. 982–985 and 994 was granted in Civil Case No. C-424; commissioners failed to act.
    • On September 9, 1996, the RTC granted a Supplemental Motion to segregate portions of Lots 23, 28-A-1 and 28-A-2, leading to issuance of TCT No. C-314537 in the name of Eleuteria Rivera (portion of Lot 23, area: 14,391.54 m²).
    • Writ of possession issued December 26, 1996; notice to vacate served on Phil-Ville and Bonifacio Shopping Center, Inc.
    • Court of Appeals (CA-G.R. SP No. 43009 and CA-G.R. SP No. 43034) set aside the 1996 RTC Order, writ and notice to vacate; Eleuteria Rivera died February 22, 1997.
    • Department Order No. 137 (April 23, 1997) and Senate Resolution No. 1032 (October 7, 1997) investigated titling anomalies.
  • Quieting-of-title action in the RTC
    • On June 5, 1997, Phil-Ville filed Civil Case No. C-507 for Quieting of Title and Damages against the surviving heirs of Eleuteria Rivera and the Register of Deeds of Caloocan City.
    • RTC, Branch 122, on March 24, 2000 ordered:
      • Quieting of TCT Nos. 270921–270923 in favor of Phil-Ville;
      • Declaration TCT No. C-314537 (Eleuteria Rivera) is null and void;
      • Cancellation of TCT No. C-314537;
      • Award of attorney’s fees to Phil-Ville.
  • Appeals and CA decisions
    • Respondents filed Notices of Appeal, later withdrew their appeal in CA-G.R. CV No. 66547; CA dismissed Danilo Bonifacio and Carmen Bernardino on October 17, 2002.
    • Respondents filed a Petition for Review on Certiorari to the Supreme Court (G.R. No. 142640), which was referred to the CA (CA-G.R. SP No. 62211).
    • On January 31, 2005, the CA set aside the RTC decision in C-507 and dismissed Phil-Ville’s complaint, ruling the RTC lacked jurisdiction as the action sought annulment of the CFI’s May 25, 1962 Order.
    • CA denied Phil-Ville’s motion for reconsideration on March 15, 2005.
  • Petition for review on certiorari
    • Phil-Ville filed this petition (G.R. No. 167391) to set aside the CA’s January 31, 2005 Decision and March 15, 2005 Resolution.
    • Petitioner’s main contentions:
      • CA acted without jurisdiction over respondents’ petition;
      • RTC had jurisdiction over a quieting-of-title action;
      • TCT No. C-314537 is invalid and does not overlap Phil-Ville’s lots.

Issues:

  • Jurisdiction of the Court of Appeals
    • Whether the CA acted with grave abuse of discretion in taking cognizance of respondents’ Petition for Review in CA-G.R. SP No. 62211 after dismissal of their appeal in CA-G.R. CV No. 66547.
  • Jurisdiction of the Regional Trial Court
    • Whether the RTC had jurisdiction to hear Civil Case No. C-507 for Quieting of Title and Damages, or whether the complaint was effectively an action for annulment of the CFI Order of May 25, 1962.
  • Existence of a cloud on title
    • Whether TCT No. C-314537 (Eleuteria Rivera) constitutes a cloud on Phil-Ville’s titles to Lots 1-G-1, 1-G-2, and 1-G-3, given its invalidity and its technical description relative to Phil-Ville’s parcels.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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