Case Digest (G.R. No. 206863)
Facts:
In the case Pryce Corporation vs. Engr. Vicente Ponce (Deceased), G.R. No. 206863, a dispute arose over the ownership of a five-hectare parcel of land in Sta. Filomena, Iligan City. The petitioner, Pryce Corporation, claimed ownership through Transfer Certificate of Title (TCT) No. 48,394, while the respondents, represented by the heirs of Vicente Ponce, claimed ownership through TCT No. T-17,464 issued in Ponce's name. The roots of this conflict date back to 1914, when Prudencio Soloza applied for a homestead patent over a 15-hectare lot in the area. Modesta Fabro opposed this application claiming prior cultivation and occupation of the land. Despite opposition, Prudencio’s application was approved in 1924.
Following Prudencio's passing in 1941, his heirs won a legal suit against the Quidlat siblings, heirs of Modesta who sought to reclaim possession. The 1954 Court of Appeals ruling affirming the heirs' title became final. After various operations and transfers of
Case Digest (G.R. No. 206863)
Facts:
- Overview of the Dispute
- The controversy involves a contested piece of real property—a five-hectare lot in Sta. Filomena, Iligan City—registered under two different Transfer Certificates of Title (TCTs).
- Respondent Vicente Ponce holds TCT T-17,464 issued in his name, whereas petitioner Pryce Corporation asserts its right through TCT T-48,394.
- The dispute centers on who has the better right to the subject property given the overlapping coverage of these titles.
- History and Transfer of the Subject Property
- The disputed land’s history dates back to 1914 when Prudencio Soloza applied for a homestead patent for a 15-hectare lot.
- Prudencio’s application was opposed by Modesta Fabro and her husband Juan Quidlat, who claimed prior cultivation since 1904.
- Despite the opposition, Prudencio was issued Homestead Patent No. H-25364 in 1924 and subsequently, Original Certificate of Title (OCT) No. 21 in 1925.
- Subsequent events included:
- Prudencio’s death in 1941 and ensuing litigation between his heirs and the Quidlat siblings over possession of the 15-hectare lot.
- A favorable ruling for Prudencio’s heirs by the Court of First Instance (CFI) and confirmation by the Court of Appeals (CA) in a 1954 decision.
- Later transfers and segmentation:
- The 15-hectare lot was later subdivided through several conveyances: cancellation of OCT RP-62(21) and issuance of TCTs in the names of Pedro Soloza, Andres Achacoso, and Lorenzo Lagandaon.
- On April 14, 1964, a five-hectare portion (the subject property) was sold eventually to Ponce, who later registered it on May 28, 1979.
- History and Transfer of the Overlapping 8.1-Hectare Lot No. 1936
- Independently, the Quidlat siblings were involved in a cadastral case concerning Lot No. 1936, originally part of the 15-hectare lot.
- They filed an answer in the cadastral proceedings (in 1955) to claim ownership.
- Events in the cadastral case include:
- Sale of Lot No. 1936 to spouses Richard and Norma Lim in 1993.
- A subsequent decision in 1994 awarding Lot No. 1936 to the Quidlat siblings.
- The issuance of OCT O-1,164 and later successive TCTs culminating with the sale of a six-hectare portion to Pryce, which was registered on January 10, 1996 under TCT T-48,394.
- As a result, there exists an overlap: Pryce’s six-hectare title intrudes on Ponce’s five-hectare subject property.
- Procedural and Judicial Developments
- At the trial level:
- Ponce instituted a complaint for quieting of title, reconveyance, and damages in 2003, alleging that his title “tapped” into Prudencio’s OCTs, which he claimed were genuine and superior by reason of “first in time, prior in right.”
- The trial court ruled in favor of Ponce based on the prior CA decision and the presumption of validity in Prudencio’s titles.
- On appeal:
- The Court of Appeals (in its August 31, 2012 Decision) affirmed the trial court’s ruling, largely relying on the chronological priority of Ponce’s title.
- The CA also denied Pryce’s motion for reconsideration in its April 18, 2013 Resolution.
- Petition before the Supreme Court:
- Pryce Corporation filed a Petition for Review on Certiorari arguing multiple grounds challenging the validity of Prudencio’s OCTs and asserting that its title registration was in good faith and superior.
- Claims and Contentions Raised by the Parties
- Ponce’s Position:
- Reliance on the 1954 CA Decision and the historical issuance of Prudencio’s titles.
- Invocation of the “first in time, prior in right” principle to assert ownership despite overlapping titles.
- Pryce’s Arguments:
- Alleged irregularities and defects in Prudencio’s Homestead Patent, OCT 21, and reconstituted OCT RP-62(21), including absence of required signatures and questionable alterations.
- The claim that Ponce’s title, being derived from these allegedly void documents, is void ab initio.
- Assertion that Pryce, as the first registrant in good faith—having completed due diligence post-finality of the cadastral case—is entitled to the subject property.
- Allegation that Ponce’s delay and laches, evidenced by his tardy complaint initiation, undermine his claim.
Issues:
- Who holds the better right to the subject property given the existence of two conflicting titles?
- Whether Prudencio’s OCT and its reconstitution (forms of the mother titles) are valid and whether the irregularities therein render Ponce’s title void.
- Whether the “first in time, prior in right” rule applies when the earlier title is void ab initio.
- Whether Pryce Corporation’s title, registered in good faith after the finality of the cadastral case, should be given priority over Ponce’s earlier registration tainted by bad faith and laches.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)