Case Summary (G.R. No. 151246)
Background of Property Ownership
The fourteen-hectare parcel of land was originally titled under Free Patent No. 6381, granted to Fernando Nantes in 1918, generating Original Certificate of Title No. 470. Following the sale of the property by Nantes to Rosendo Farales, and then to Apolinario Fama in 1931, the title was transferred to TCT No. 257 and subsequently reconstituted as TCT No. RT-223 (257) after the original title was allegedly lost in 1947.
Previous Legal Proceedings
Prior to the current case, Maria Fama Florentin, as one of the heirs, filed a case against Lazaro Galera in 1950 to recover an 11,000-square-meter portion of the land, claiming ownership based on the title. The court ruled in favor of Fama, dismissing Galera's claims, which he contested up to the Supreme Court, but ultimately, the judgment against him was upheld, barring any further claims of ownership.
Complaints Filed
In 1974, the petitioners filed a complaint for recovery of possession against the respondents, who claimed to have occupied the land since time immemorial, alleging their ownership based on continuous possession and improvements made to the land. Another legal action concerning quieting of title and partition was initiated by the respondents in 1984.
Decisions of the Lower Courts
The Regional Trial Court (RTC) ruled in favor of the petitioners in 1997, asserting the priority of title based on the Torrens system and rejecting the claims of adverse possession put forth by the respondents. The RTC highlighted that the respondents had not made an adverse claim within the legally stipulated period, hence they were guilty of laches.
Court of Appeals Ruling
Conversely, the Court of Appeals (CA) reversed the RTC's decision in 2001, ruling that the respondents provided overwhelming evidence of long-standing and uninterrupted possession of the property prior to the petitioners' title issuance. It held that the petitioners had allowed too much time to pass to assert their claim, rendering their action barred by laches and dismissing the RTC's ruling.
Petitioners' Arguments on Appeal
The petitioners contended that their claim was not barred by laches, as Apolinario Fama had asserted ownership over the property for decades. They emphasized the indefensibility of their Torrens title and argued that mere possession of the land by the respondents could not overshadow their legal ownership.
Supreme Court's Analysis
The Supreme Court ruled that the respondents’ historical possession did not supersede the legal title granted under the Torrens system. The Court reaffirmed t
...continue readingCase Syllabus (G.R. No. 151246)
Background of the Case
- The case concerns a dispute over a seven-hectare portion of a fourteen-hectare parcel of land in Pugo, La Union.
- The petitioners are the heirs of Apolinario Fama, the registered owner, while the respondents are various occupants claiming ancestral possession.
- The land was originally surveyed by Fernando Nantes, who was granted a free patent and original certificate of title in 1918.
Historical Transactions
- In 1930, Fernando Nantes sold the entire property to Rosendo Farales, who subsequently sold it to Apolinario Fama in 1931.
- Apolinario Fama's title was formalized as Transfer Certificate of Title (TCT) No. 257.
- In 1947, following the loss of TCT No. 257, Maria Fama Florentin sought its reconstitution, which led to the issuance of TCT No. RT-223 (257) in 1948.
Initial Legal Actions
- In 1950, Maria Fama Florentin filed a case against Lazaro Galera, a predecessor of one of the respondents, to recover an 11,000-square meter portion of the land.
- Galera claimed ownership through a donation from his father and accused Nantes of fraud in obtaining the title.
- The Court of First Instance ruled in favor of Fama, determining there was no evidence of fraud, and Galera's appeal was dismissed by the Supreme Court in 1962.
Demand for Vacate and Subsequent Complaints
- The petitioners sent demand letters to the respondents to vacate the land in 1972, which we