Case Summary (G.R. No. 223763)
Case Background
The dispute arose from a complaint filed by petitioners against respondent for reconveyance, accion publiciana, and cancellation of title with damages concerning a 12,459-square meter parcel of land located at West Dirita, San Antonio, Zambales. Claiming to be direct descendants of Eduveges Bafiaga, the petitioners sought to recover the land currently titled to Perla Callo (respondent) under Original Certificate of Title No. P-24666, which they alleged was fraudulently obtained.
Historical Context of the Property
Eduveges Bafiaga, who passed away in 1921, left several parcels of land including the subject lot, which was recognized as belonging to his heirs. A Final Project of Partition executed in 1973 awarded the property to petitioners as descendants of Eduveges' daughter, Rufina Pascasio. The institution of mortgage over the land by Rufina's children to respondent and her husband in the early 1970s set the stage for subsequent disputes over ownership and claims of possession.
Legal Proceedings and Rulings
The Regional Trial Court (RTC) ruled in favor of petitioners on July 5, 2011, finding that respondent committed fraud by misrepresenting her ownership when obtaining a certificate of title. The RTC declared respondent’s title null and void, granting reconveyance to petitioners. In contrast, the Court of Appeals (CA) reversed this ruling on September 30, 2015, asserting that petitioners failed to provide adequate proof of their claim and dismissed the case. The petitioners’ motion for reconsideration was also denied in a March 18, 2016 resolution.
Supreme Court’s Review
The Supreme Court primarily addressed whether the CA erred in dismissing the complaint filed by the petitioners. The Court found that respondent's acquisition of the property through a free patent was flawed due to her admission of obtaining the property through a mortgage arrangement rather than through conditions required for free patent applications as set forth in Commonwealth Act No. 141, specifically that:
- The applicant (respondent) must prove continuous possession and cultivation of the land in the concept of ownership for at least thirty years.
- The applicant or predecessors must have paid real estate taxes prior to unauthorized occupation by others.
Findings on Ownership and Title
The Supreme Court determined that respondent lacked a legitimate claim to the land as her possession was predicated on a previous mortgage, which was redeemed by the petitioners. Her failure to acknowledge this in her free patent application constituted fraud, leading to the cancellation of her title.
Legal Implications
The Court emphasized that the title granted under the Torrens system does not impart ownership but merely ser
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Case Overview
- This case involves a petition for review on certiorari by petitioners Adoracion L. Basilio and Lolita P. Lucero, challenging the Decision dated September 30, 2015, and the Resolution dated March 18, 2016, of the Court of Appeals (CA) in CA-G.R. CV No. 97617.
- The CA's decision reversed the Regional Trial Court's (RTC) ruling that had favored the petitioners in their complaint for reconveyance, accion publiciana, and cancellation of title with damages against respondent Perla Callo.
Background and Facts
- The controversy arose from a complaint filed by the petitioners in the RTC to recover a 12,459-square meter parcel of land designated as Lot No. 4462, located at West Dirita, San Antonio, Zambales.
- Petitioners claimed to be direct descendants of Eduveges Bafiaga, who died intestate, leaving various parcels of land, including the subject lot, declared under his name.
- In 1971, Librada Lucero, one of the petitioners' relatives, mortgaged a portion of the subject lot to the spouses Edilberto and Perla Callo, leading to further mortgages and claims regarding ownership.
- Petitioners argued that the respondent's title was obtained through fraud, as they discovered that the subject lot was registered in respondent's name under Original Certificate of Title No. P-24666.