Case Summary (G.R. No. 236619)
Antecedents
In August 2006, Jennifer Eaano Bote, daughter of the deceased Manuel Eaano, empowered her husband Virgilio to file a Complaint for Quieting of Title concerning the subject property, which was allegedly registered under Transfer Certificate of Title (TCT) No. T-35050 in Manuel's name. The petitioners claimed that Manuel possessed the property since 1966 until his death in 1987, after which they continued his possession. Meanwhile, the respondent claimed ownership through TCTs T-309608, T-309609, and T-309610. Upon investigation, the petitioners learned that the respondent's TCTs were fictitious, prompting their legal action.
Regional Trial Court Decision
The Regional Trial Court (RTC) of San Pedro ruled in favor of the petitioners on June 20, 2014, affirming their ownership of the subject property. The court based its ruling on the evidence presented by the petitioners, which indicated that Manuel had a valid title and continuous possession. The RTC deemed the respondent's titles void since they were unsupported by adequate evidence from the land registration authorities.
Court of Appeals Ruling
On August 15, 2017, the Court of Appeals (CA) reversed the RTC's decision, asserting that the petitioners failed to demonstrate a legal or equitable title over the property. The CA ruled that the petitioners' allegations regarding the fictitious nature of the respondent's titles did not hold against the established chain of transactions leading to the respondent’s ownership. The CA also noted that significant records indicated that Manuel's TCT was canceled and pertained to a different property altogether.
Issues Before the Supreme Court
In the petition submitted for a review, the petitioners raised multiple issues, including the CA's alleged errors in disregarding the evidence of the petitioners' ownership, the validity of the titles, and Virgilio's authority to file the case. The petitioners contended that the titles held by the respondent were products of a fraudulent reconstitution that did not actually occur.
Supreme Court's Ruling
The Supreme Court denied the petition, affirming the CA's decision. The Court emphasized that legal ownership requires proper evidence of title, which the petitioners failed to establish. The Court reiterated the two necessary requisites for an action for quieting of title: the plaintiff must have a legal or equitable title to the property, and the alleged
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Case Background
- This case is a Petition for Review on Certiorari concerning the reversal of the decision of the Regional Trial Court (RTC) of San Pedro, Laguna, by the Court of Appeals (CA).
- The CA's decision dated August 15, 2017, dismissed the petitioners' Complaint for Quieting of Title with Damages due to lack of merit.
- The underlying issue revolves around the ownership of a parcel of land measuring approximately 74,847 square meters located at Barangay Landayan, San Pedro, Laguna.
Parties Involved
- Petitioners: Heirs of Manuel Eaano, represented by Virgilio A. Bote.
- Respondent: San Pedro Cineplex Properties, Inc.
Antecedents
- Jennifer Eaano Bote, daughter of Manuel Eaano, authorized her husband, Virgilio, to file a complaint for quieting of title.
- Petitioners claimed that Manuel was the registered owner of the subject property, supported by Transfer Certificate of Title No. T-35050 (TCT No. T-35050).
- Manuel had occupied the property openly and continuously since 1966 until his death in 1987, after which his heirs continued possession.
- In June 2006, the respondent filed a Complaint for Forcible Entry claiming ownership based on TCT Nos. T-309608, T-309609, and T-309610, which were later discovered to be fictitious.
Proceedings in Lower Courts
- The RTC initially ruled in favor of the petitioners, declaring them the exclusive owners of the subject property and nullifying the respondent's titles.
- The CA later reversed this ruling, stating that the petitione