Case Summary (G.R. No. 244405)
Factual Antecedents
Juan Salva, the registered owner of a parcel of land in Cagayan, died intestate in 1945, leaving behind diverse lots, including Lot 2006. Angela Cudal, claiming to be Salva's granddaughter, executed an Affidavit of Adjudication and Sale in 1969 to claim the entire estate and subsequently sold parts of Lot 2006 to Isabelo Cudal, Sr. and Antonio Cudal. Controversy arose when Visitacion Pancho, another alleged heir, executed a Confirmation of Ownership in 1975, which she registered, leading to the issuance of a new title to Jose Say and, later, a series of sales that resulted in the respondents acquiring the property.
Trial Court Ruling
The Regional Trial Court (RTC) ruled in favor of the petitioners, invalidating Pancho's Confirmation of Ownership due to lack of validity and stating that she was not a true heir. The RTC determined that the respondents could not be considered purchasers in good faith, emphasizing the petitioners’ prior ownership and possession of Lot 12. The court also upheld that the action to quiet title does not prescribe and ruled that petitioners acted promptly once aware of respondents' title.
Court of Appeals Ruling
Upon appeal, the Court of Appeals overturned the RTC's ruling, asserting that Marcelino had exercised due diligence as he inspected the property and engaged in discussions with Libertad Cudal. The CA concluded that respondents qualified as buyers in good faith as they were unaware of other claims prior to their purchase. It noted that petitioners failed to register their claim effectively, thereby weakening their position against respondents.
Key Legal Issues
The pivotal legal questions included whether the respondents genuinely acted as innocent purchasers for value and the validity of the claims stemming from the separate actions of Angela Cudal and Visitacion Pancho regarding ownership of Lot 12. The appeals court's analysis focused on the good faith of the respondents in purchasing the property amid existing claims from the petitioners.
Supreme Court's Ruling
The Supreme Court ultimately granted the petition of the heirs of Isabelo and Antonio Cudal, finding that the respondents were not buyers in good faith as they were aware of the petitioners' possession and purported claims when they decided to purchase Lot 12. The court explained that respon
...continue readingCase Syllabus (G.R. No. 244405)
Case Citation
- G.R. No. 244405
- August 27, 2020
- 880 Phil. 347
- First Division
Parties Involved
- Petitioners: Heirs of Isabelo Cudal, Sr. represented by Libertad Cudal, and Heirs of Antonio Cudal represented by Victoriano Cudal.
- Respondents: Spouses Marcelino A. Suguitan, Jr. and Mercedes J. Suguitan.
Procedural History
- The case originated from a Petition for Review on Certiorari under Rule 45 of the Rules of Court.
- The petition challenges the Decision dated July 20, 2018, and Resolution dated January 11, 2019, issued by the Court of Appeals (CA) in CA-G.R.CV No. 107522.
Factual Antecedents
- Property in Dispute: A 154,344-square meter parcel of land (Lot H-5865) in Nabaccayan, Gattaran, Cagayan, originally registered under Juan Salva’s name with Original Certificate of Title (OCT) No. P-283 issued on June 22, 1925.
- Inheritance Claims:
- Angela Cudal executed an Affidavit of Adjudication and Sale on May 30, 1969, claiming to be Juan Salva's granddaughter and sole heir, selling portions of Lot 2006 to Isabelo Cudal, Sr. and Antonio Cudal.
- Visitacion Pancho executed a Confirmation of Ownership on July 8, 1975, renouncing her rights to a portion of Lot 2006 in favor of Jose Say, who registered the ownership and was later involved in further transactions leading to the respondents acquiring a title.
RTC Ruling
- The Regional Trial Court (RTC) ruled in favor of the petitioners, declaring that Visitacion could not validly convey her rights due to her lack of heirship.
- It maintained that respo