Case Digest (G.R. No. 144208)
Case Digest (G.R. No. 144208)
Facts:
Efren Tandog, Felix Tandog, Felipe Tandog, Josefino Tandog, Helen Tandog, Catalina Tandog, Romeo Tandog, Domingo Tandog, Catalina Santos, Maria Bautista Catanyag, Artemio Catanyág, Angeles Catanyag, Apolonia Catanyag, Adoracion Catanyag, Arcely Catanyag, and Amparo Catanyag, all represented by Efren Tandog, v. Renato Macapagal, Spouses Alfonso and Marina Calderon, and the Lands Management Bureau, G.R. No. 144208, September 11, 2007, the Supreme Court First Division, Sandoval‑Gutierrez, J., writing for the Court.The dispute concerns a parcel of land of 147,991 square meters in Sitio Inarawan, Barangay Inuman, San Isidro, Antipolo City. The petitioners claimed longstanding, continuous, exclusive possession of the property through succession from Casimiro Policarpio (deceased 1945) and asserted that they and their predecessors had cultivated and occupied the land since time immemorial.
In the course of preparing for judicial registration, petitioners discovered that portions of the property were in the possession of respondents. Spouses Alfonso and Marina Calderon occupied about 20,116 square meters and allegedly relied on falsified documents; they had sold their portion to the government. Renato Macapagal had applied for and received Free Patent No. 045802‑1165, resulting in Original Certificate of Title (OCT) No. P‑665 covering 18,787 square meters. Petitioners filed a complaint for quieting of title in the Regional Trial Court (RTC), Branch 73, Antipolo City, docketed as Civil Case No. 92‑2418.
Before trial, on July 20, 1993, petitioners and Macapagal entered a compromise agreement in which petitioners acknowledged his ownership over the area covered by OCT P‑665; the trial court approved that compromise. During trial, after petitioners presented evidence, spouses Calderon filed a demurrer to evidence; in an Order dated March 20, 1995 the RTC granted the demurrer and dismissed the complaint.
Petitioners appealed to the Court of Appeals (CA). In a Decision dated July 31, 2000 in CA‑G.R. CV No. 57812, the CA affirmed the RTC, holding that petitioners failed to show a cloud on title under Article 476 of the Civil Code, that the purported falsified documents were only marked but not formally offered, and that petitioners’ testimony was largely hearsay failing to establish pedigree or legal/equitable title. Petitioners then filed a Petition for Review on Certiorari under Rule 45 to the Supreme Court, challenging the CA’s affirmation of the RTC dismissal.
Issues:
- Did petitioners prove a removable cloud on title sufficient to maintain an action for quieting of title under Article 476 of the Civil Code?
- May documents that were marked but never formally offered in evidence be considered to prove a cloud on title?
- Did petitioners establish legal or equitable title, including the requisite proof of pedigree, to sustain their action for quieting of title?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)