Title
Supreme Court
Heirs of Delfin vs. Rabadon
Case
G.R. No. 165014
Decision Date
Jul 31, 2013
Respondents proved ownership of Lot No. 8217 via Decree No. 98992; petitioners' tax declarations and laches defense insufficient. SC affirmed CA ruling favoring respondents.

Case Summary (G.R. No. 165014)

Facts of the Case

On October 19, 1993, the respondents initiated an action against the petitioners in the Regional Trial Court (RTC) to reclaim ownership and possession of the subject property, as well as seek damages. They asserted that the land was originally owned by their predecessor, Emiliana Bacalso, as per Decree No. 98992, although the physical decree was supposedly lost during World War II. They presented evidence, including Land Registration Authority (LRA) certification and a daybook entry, to establish their claim, and claimed continued possession until 1988. The petitioners contended that they inherited the property from Remegio Navares, asserting that it was rightfully purchased before the war, despite lacking strong documentation, such as a deed of sale.

Ruling of the RTC

The RTC, in its decision dated June 27, 1997, ruled in favor of the petitioners, acknowledging their claim stemming from tax declarations and payments for the subject property. It noted that while tax declarations do not solely prove ownership, they can imply it when combined with continuous possession. The RTC observed that the respondents failed to take necessary actions to locate their purported title and noted laches on their part for the 55-year delay in claiming ownership.

Ruling of the CA

The Court of Appeals (CA) reversed the RTC's decision on February 28, 2001, finding that the respondents held superior rights to ownership and possession. It highlighted the weakness of the petitioners' evidentiary support, primarily tax declarations, which were deemed inadequate in the absence of proof of actual possession. The CA emphasized the importance of Decree No. 98992, which purportedly establishes the land's ownership, over the petitioners' claims, concluding that respondents demonstrated prior possession and rightful ownership.

Issue Before the Supreme Court

The primary issue at hand was whether the respondents had a superior claim to the ownership and possession of Lot No. 8217 in comparison to the petitioners.

Supreme Court's Ruling

The Supreme Court affirmed the CA's decision, citing that the respondents proved a better claim through Decree No. 98992. The Court noted that a decree of registration bars all claims that arose before its issuance, emphasizing the definitive nature of ownership established by such decrees. The Court found that the petitioners could not substantiate their

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