G.R. No. 123509 - Robles vs. Court of Appeals

Leon Robles originally owned the parcel of land in Kay Taga, Lagundi, Morong, Rizal, as evidenced by a 1916 tax declaration (No. 17865), and he occupied the land openly and adversely.
Upon Leon Robles’ death, his son Silvino Robles inherited the property, assumed possession, declared the land in his name for taxation purposes, and paid the corresponding taxes.
After Silvino’s death in 1942, his widow Maria de la Cruz and his children (including petitioners) inherited the property, took adverse possession, and continued to pay taxes on it.
Petitioner Lucio Robles was tasked with cultivating the land (planting trees, other crops, and constructing a nipa hut), while the payment of land taxes was entrusted to their co-heir and half-brother, Hilario Robles.

In 1962, the tax declaration in Silvino Robles’ name was canceled and transferred to one Exequiel Ballena, allegedly without a corresponding deed of conveyance from the heirs of Silvino.
Exequiel Ballena subsequently used the tax declaration as collateral to secure a loan from the Antipolo Rural Bank, after which the declaration passed to the Rural Bank of Cardona, Inc., and later to Hilario Robles and his wife.
In 1996, Andrea Robles (wife of Hilario) secured a loan from Cardona Rural Bank using the same tax declaration as security, with testimony indicating that someone else (not Hilario) signed the loan documents.

Due to failure to pay the mortgage debt, foreclosure proceedings were initiated, and in October 1968 the Rural Bank emerged as the highest bidder in the auction sale.
The spouses Vergel Santos and Ruth Santos acquired the property from the Rural Bank of Cardona, Inc. in September 1987, took possession, and eventually secured Free Patent No. IV-1-010021 in their names.
Petitioners discovered the existence of the mortgage and foreclosure only after the Santos spouses had taken possession, prompting their legal action.

Petitioners Lucio, Emeteria, Aludia, and Emilio Robles filed an action for quieting of title on March 14, 1988, in the Regional Trial Court of Morong, Rizal, contending that their title was clouded by subsequent transactions including the issuance of a free patent to the Santos spouses.
The trial court’s decision ordered:

The nullity of Free Patent No. IV-1-010021;
The delivery of the property to the petitioners; and
The declaration that the heirs of Silvino Robles were the absolute owners of the land.

The Court of Appeals later reversed the trial court’s decision, holding that the petitioners had lost title by prescription and that certain transfers (e.g., tax declarations and deed of sale) evidenced a transfer of title, effectively undermining their claim.

Whether the petitioners, as heirs and occupants of the property since 1916, had a legal or equitable title sufficient to avail of the remedy of quieting of title.
Whether their continuous occupation and adverse possession established their claim despite the subsequent transfers evidenced by tax declarations and other instruments.

Whether the real estate mortgage executed by Hilario Robles was valid, given allegations (supported by Andrea Robles’ testimony) of forgery regarding Hilario’s signature.
Whether the bank’s failure to exercise due diligence in verifying the true ownership of an unregistered property rendered the mortgage (and the subsequent foreclosure sale) null and void as it affected the petitioners’ interests.

Whether the issuance of Free Patent No. IV-1-010021 was valid, considering that the land had been in private possession and was no longer part of the public domain.
Whether the authority of the Director of Lands extended to adjudicating and disposing of land that had already undergone privatization through adverse possession.

Whether prescription had operated against the petitioners due to their inaction relative to their half-brother’s transaction, and if a co-owner can acquire title by prescription in the absence of clear repudiation of co-ownership.
Whether the acts (such as the mortgage and tax declarations) by Hilario Robles could be interpreted as a repudiation of the co-ownership that would bar the petitioners from asserting their rights.