G.R. No. 159116 - Spouses Dadizon vs. Court of Appeals

The dispute involves a parcel of land originally measured at 224 square meters, which, through a series of transactions and tax declarations, eventually became the subject of contention between the Mocorros and the Dadizons.
The property history can be traced back to Ignacia Bernal who owned a large tract of land declared in Tax Declaration No. 504.
On December 30, 1946, Ignacia Bernal sold 364 square meters of her land to Almeda Elaba, leading to the issuance of Tax Declaration No. 1551 (covering 224 square meters).
On May 29, 1971, Elaba sold the 224 square meter portion to Brigido Caneja, Sr., resulting in the issuance of Tax Declaration No. 4301 in 1972.
On June 2, 1973, Caneja, Sr. sold the land to the Mocorros, with Tax Declaration No. 4518 (later superseded by Tax Declaration No. 3478 in 1979) being issued in their favor.

In 1984, the Mocorros’ land area was reduced from 224 square meters to 146 square meters by an administrative adjustment that excluded 78 square meters.
The excluded 78-square meter area later became the subject of dispute when the Dadizons, who had been issued their own tax declaration (Tax Declaration No. 535, covering 147 square meters in 1980), claimed ownership.
The Dadizons’ property boundaries, as stated in their tax declaration, bordered the Mocorros’ lot, with annotations noting that the previous tax declaration was “unidentified” and “subject for further verification.”

The Mocorros traced their title through a chain of transactions beginning with the purchase from Caneja, Sr. on June 2, 1973, and further evidenced by the issuance of successive tax declarations.
Additionally, the Mocorros had constituted a mortgage on the property in favor of the Rural Bank of Naval in July 1975, with the mortgage annotation appearing on Tax Declaration No. 3478.
The Dadizons, on the other hand, based their claim on an unnotarized and unregistered deed of absolute sale of real property executed on March 10, 1976 by Eustaquia Bernadas, their mother, which purportedly transferred a 78-square meter portion of the lot to them.
The Dadizons also presented an affidavit of adjoining owners and relied on a series of prior transactions involving Ignacia Bernal, which allegedly traced a separate chain of title to the disputed portion.

The Municipal Trial Court (MTC) of Naval, Biliran, initially resolved the dispute by granting a judgment on December 6, 1999 in favor of the Mocorros, holding that:

The 78-square meter area was part of the parcel sold to the Mocorros.
Evidence showed that the Mocorros’ title and possession predated the Dadizons’ claim, and the latter’s documents were fraught with inconsistencies—including the failure to notarize the transaction.

The Regional Trial Court (RTC) affirmed the MTC decision on May 17, 2001, giving weight to the trial court’s factual findings and the credibility of its witnesses.
The Dadizons subsequently filed an appeal with the Court of Appeals (CA) using a notice of appeal, which the Mocorros contested on the ground that the appeal was erroneously taken.

The Court of Appeals dismissed the Dadizons’ appeal via its resolution dated February 26, 2003, holding that the mode of appeal adopted was improper.
A subsequent motion for reconsideration by the Dadizons was denied on June 30, 2003.
The central factual controversy was whether the unregistered and unnotarized deed of absolute sale executed by Bernadas could affect the rights of third parties (i.e., the Mocorros) and whether it could bind them despite being the sole document relied upon by the Dadizons.

Whether the mere execution of the deed of sale covering an unregistered parcel of land was sufficient to convey title or bind third parties.
Whether the requirement of registration is an indispensable element in the transfer of title for unregistered lands under the Property Registration Decree (Presidential Decree No. 1529).

Whether the Dadizons properly adopted the correct mode of appeal in challenging the decision of the RTC given that they filed a notice of appeal rather than a petition for review.
Whether the errors in the mode of appeal were fatal to their case and justified the dismissal by the Court of Appeals.