Case Summary (G.R. No. 198677)
Nature of the Case and Disputed Property
The case involves a dispute over ownership and possession of a 12,189-square-meter parcel of land (Lot No. 1950-A of the Naic Estate) situated in Naic, Cavite. The petitioner, Rodolfo L. Coronel, claimed ownership based on Transfer Certificate of Title (TCT) No. T-75543 issued in his name after purchasing the property from Mariano Manalo and Jorga Manalo. The respondents, heirs of Gabriel Merlan, claimed a 1/3 undivided share of Lot No. 1950-A, asserting they never sold their portion and have been in open, peaceful, and adverse possession of it.
Facts on Ownership and Prior Transactions
The original Lot No. 1950 was co-owned by various heirs, including Bernabela Lontoc who owned 2/8 of the lot. Upon Lontoc’s death, her heirs—including the Merlan siblings (Gabriel’s children)—inherited her share. In 1950, some co-heirs (Bernardino Merlan, Daniel Anuat, Paz Anuat) sold their 2/3 undivided interest of Lontoc's portion to Ignacio Manalo and Marcela Nobelo. The Merlan brothers did not sell their 1/3 share.
Subsequent land subdivision in 1968 transformed Bernabela Lontoc’s 2/8 portion into Lot No. 1950-A. Ignacio Manalo later sold his 2/3 interest to Mariano Manalo, whose title was registered covering the entire Lot No. 1950-A, mistakenly including the respondents’ 1/3 undivided share.
Litigation and Court Decisions
Petitioner Coronel filed an action for recovery of possession based on the Torrens title he acquired, while respondents disputed his claim and asserted their ownership and possession of the 1/3 share. The trial court ruled in favor of the respondents, ordering partition of the land according to the original undivided shares and requiring an accounting of harvests from the property.
The Intermediate Appellate Court affirmed the decision with a modification recognizing the respondents as absolute owners of the 1/3 undivided portion pursuant to Article 845 of the New Civil Code. It rejected the petitioner’s claims that respondents’ rights were barred by prescription or laches, and upheld the respondents’ quiet possession and ownership.
Issues Raised by Petitioner
- That respondents’ claims were barred by statute of limitations or estoppel by laches due to their failure to assert ownership in a timely manner.
- That petitioner was a purchaser in good faith for valuable consideration.
- That the cancellation of TCT No. T-75543 in favor of petitioner was erroneous and should be upheld.
Legal Analysis on Prescription, Laches, and Ownership
The Court held that the respondents' claim was not barred by prescription. As peaceful possessors having exercised ownership for over 25 years, the respondents' action to quiet title was imprescriptible. Their cause of action only accrued when petitioner filed his complaint in 1975. The Courts likewise rejected the claim of laches, noting no unreasonable delay or neglect on the respondents’ part given their continuous possession.
Regarding petitioner’s claim of good faith purchase, the Court emphasized that good faith does not equate to ownership where a rightful co-owner’s share was never sold. The issuance of TCTs covering the entire parcel including the respondent’s undivided share was a mistake or oversight. The Court reiterated the well-established principle in Torrens syste
Case Syllabus (G.R. No. 198677)
Case Background and Parties Involved
- Petitioner Rodolfo L. Coronel filed a complaint for recovery of possession of a parcel of land identified as Lot No. 1950-A, Naic Estate, situated in Naic, Cavite, covered by Transfer Certificate of Title (TCT) No. T-75543.
- Coronel alleged ownership over the entire parcel, acquired via a deed of sale from spouses Mariano Manalo and Jorga Manalo, successors-in-interest of Ignacio Manalo and Marcela Nobelo.
- Respondents Elias Merlan, Brigido Merlan, Jose Merlan, and others, counterclaimed ownership over a 1/3 undivided share of Lot No. 1950-A, inherited from their deceased father Gabriel Merlan, himself heir to Bernabela Lontoc, the original registered owner.
- The defendants claimed the 1/3 share was never sold, maintained peaceful possession, and the title transfers covering the whole lot were improper as they fraudulently or mistakenly included their undivided portion.
Facts Pertaining to Title History
- Lot No. 1950 was originally a 48,755 square meter parcel subdivided with ownership divided into calculated portions: 2/8 to Bernabela Lontoc, among others.
- Bernabela Lontoc’s 2/8 portion of this lot equated to approximately 12,189 square meters, designated Lot No. 1950-A after subdivision approval in 1969.
- Upon Bernabela Lontoc’s death in 1945, her heirs included the Merlan siblings and other co-heirs.
- In 1950, 2/3 of Lontoc's heirs sold their shares to Ignacio Manalo and Marcela Nobelo, while the Merlan brothers maintained their 1/3 undivided portion intact and in possession.
- Title No. RT-5010 was canceled and replaced by TCT No. T-1444 in 1960, reflecting the sale annotations but mistakenly including the Merlan’s undivided 1/3 portion.
- Ignacio Manalo subsequently sold the entire portion he acquired (2/3 undivided shares) to Mariano Manalo, who became registered owner under TCT No. T-41175 covering the entire Lot No. 1950-A.
- Petitioner Coronel purchased Lot No. 1950-A from Mariano Manalo in 1974, resulting in issuance of TCT No. T-75543 in Coronel’s name for the entire parcel.
Issues Raised by Petitioner and Petition
- The petitioner alleges errors on the part of the Intermediate Appellate Court in:
- Failing to apply the statute of limitations or estoppel (laches) against respondents’ claim to the disputed land.
- Not recognizing the petitioner as a purchaser in good faith and for valuable consideration.
- Erroneously declaring the Transfer Certificate of Title No. T-75543 null and void.
- Petitioner contended the respondents’ claims are barred by prescription or laches due to delay exceeding twenty-five years since the initial sale.
- Petitioner emphasized the clear and unencumbered nature of the title he acquired, relying on registration records and absence of recorded liens or encumbrances.
Respondents’ Contentions and Legal Position
- Respondents claimed:
- Their 1/3 undivided ownership share was inherited and never sold.
- They were in open, peaceful, and adverse possession of their share for over 25 y