Title
Heirs of Enano vs. San Pedro Cineplex Properties, Inc.
Case
G.R. No. 236619
Decision Date
Apr 6, 2022
Heirs of Manuel EAano claimed ownership of a Laguna property under TCT No. T-35050, alleging respondent's titles were fictitious. SC upheld CA, ruling petitioners failed to prove legal/equitable title; respondent's titles valid.
ownership dispute
parcel of land
chain of transactions

Case Summary (G.R. No. 236619)

Factual Background

The subject of the litigation was a parcel of land estimated at 74,847 square meters located in Barangay Landayan, San Pedro, Laguna (the subject property). Petitioners asserted that Manuel H. Enano acquired the property by Deed of Absolute Sale dated May 13, 1965, and that Transfer Certificate of Title TCT No. T-35050 was issued in his name. Manuel allegedly occupied the land continuously from 1966 until his death in 1987, after which his heirs took possession. In 1994, San Pedro Cineplex Properties, Inc. was registered with the SEC, and in 1994 respondent obtained Transfer Certificates of Title TCT Nos. T-309608, T-309609, and T-309610 which the petitioners later alleged were fictitious and clouded Manuel’s title.

Early Proceedings and Parallel Ejectment Case

In June 2006 respondent filed a Complaint for Forcible Entry before the Municipal Trial Court of San Pedro. The MTC found that respondent constructively possessed the subject property and ordered petitioners and Virgilio to vacate land covered by the respondent’s TCTs. The RTC reversed the MTC, but the Court of Appeals reinstated the MTC decision. The Supreme Court, in an earlier resolution (Bote v. San Pedro Cineplex Properties Corporation, G.R. No. 180675), remanded the ejectment matter to the MTC to determine which certificates of title actually covered the disputed property and to grant possession to the proper party; on remand the MTC, by Order dated February 16, 2011, again sustained its finding that respondent physically and legally possessed the subject property.

Complaint for Quieting of Title and Pretrial Stipulations

In August 2006 petitioners, through a Special Power of Attorney executed by petitioner Jennifer Enano Bote in favor of her husband Virgilio A. Bote, filed a Complaint for Quieting of Title with Damages in the RTC of San Pedro. During pretrial the parties stipulated, among other matters, that respondent was registered under SEC Registration No. 007128 on August 9, 1994; that a decision in the ejectment case existed; and that the certificates of title at issue existed. Trial on the merits then proceeded.

Parties’ Proofs and Competing Genealogies of Title

Petitioners offered the May 13, 1965 Deed of Absolute Sale to Manuel, TCT No. T-35050, and Tax Declaration No. 24-0007-12938, and presented testimony and a judicial affidavit asserting continuous possession and tax payments. Petitioners contended that respondent’s TCTs derived from an unnotarized and undated Deed of Sale between respondent and La Paz Housing Development Corporation, and that La Paz Housing’s TCTs were products of a reconstitution proceeding that never occurred, rendering respondent’s titles fictitious. Respondent presented a contiguous chain of documentary titles starting from Original Certificate of Title OCT No. 0-217 in the name of Gliceria Kasubuan, through sales to the Spouses Sibulo and to Dona Crisanta Investment and Development Corporation, then to La Paz Housing (TCT Nos. T-129577, T-129578, T-129579), and finally to respondent by a Deed of Sale in 1994 resulting in respondent’s TCT Nos. T-309608, T-309609, and T-309610. Respondent also asserted that Manuel’s TCT No. T-35050 actually covered a 219-square-meter property in Barrio Mayapa, Calamba, registered under Marcelo P. Karran.

Ruling of the Regional Trial Court

The RTC, in its June 20, 2014 Decision, found that petitioners had the better right to the subject property and declared TCT Nos. T-309608, T-309609, and T-309610 null and void, upholding the validity of TCT No. T-35050 and the tax declaration. The trial court emphasized Manuel’s acquisition by Deed of Sale, his continuous possession, the absence of records of any petition for reconstitution underlying respondent’s titles in the Clerk of Court-RTC, the National Printing Office, and the Land Registration Authority, and the trial court’s finding that respondent failed to present credible witnesses, including the Register of Deeds, to demonstrate how respondent acquired its titles. The RTC awarded attorney’s fees of One Hundred Thousand Pesos (Php100,000.00) and costs.

Ruling of the Court of Appeals

The Court of Appeals, in its August 15, 2017 Decision, reversed and set aside the RTC judgment and dismissed the Complaint for lack of merit. The CA concluded that petitioners failed to prove by a preponderance of evidence that they had legal or equitable title. The appellate court found that Manuel’s TCT No. T-35050 had been cancelled and covered a different, 219-square-meter property, and that the mother title OCT No. 0-217 and the subsequent chain of TCTs culminating in respondent’s titles were confirmed by the records of the Register of Deeds. The CA held that the tax declaration was not proof of ownership and that respondent’s physical and legal possession had been established in the ejectment proceedings. The CA therefore ruled that no cloud existed over respondent’s titles.

Issues Raised on Certiorari

Petitioners advanced principal assignments of error asserting that the CA gravely erred by reversing the RTC, that petitioners had proved legal or equitable title and that respondent’s titles were fictitious because they derived from La Paz Housing’s alleged spurious reconstituted titles. Petitioners also defended the personality of Virgilio A. Bote to institute the action under the Special Power of Attorney and argued that impleading other heirs was unnecessary under co-ownership principles. Respondent maintained the authenticity of its titles, urged that petitioners had no legal or equitable title, asserted that the complaint impermissibly collaterally attacked respondent’s certificates of title, and pleaded res judicata.

Supreme Court’s Legal Framework and Preliminary Observations

The Court reiterated the two requisites for an action for quieting of title under Articles 476 and 477, Civil Code of the Philippines: first, the plaintiff must have a legal or equitable title or interest in the subject property; second, the instrument, record, claim, encumbrance, or proceeding asserted to cast a cloud must be shown to be in truth invalid, void, or inoperative despite its prima facie appearance of validity. The Court recognized the procedural principle that any co-owner may sue to protect rights over co-owned property without impleading others unless the suing co-owner repudiates co-ownership by claiming sole ownership; it found Virgilio A. Bote had the authority to institute the case by virtue of a Special Power of Attorney executed by his wife, one of Manuel’s heirs. The Court also reiterated the axiom that documentary evidence prevails over testimonial evidence.

Supreme Court’s Analysis and Reasons for Affirmance

Applying the statutory requisites, the Court concluded that petitioners failed to establish either requirement. First, petitioners did not satisfactorily prove they held legal or equitable title: the primary certificate relied upon, TCT No. T-35050, was found by the appellate court and supported by the record to be a cancelled title covering a distinct 219-square-meter parcel in Barrio Mayapa, Calamba, and thus did not establish registered ownership of the subject property. The tax declaration and tax payments were insufficient to constitute legal or equitable title, as tax declarations are indicia of posse

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