Title
Heirs of Tappa vs. Heirs of Bacud
Case
G.R. No. 187633
Decision Date
Apr 4, 2016
Spouses Tappa claimed ownership of Lot No. 3341 via free patent, but SC ruled their title void as the land was private. Respondents acquired ownership through acquisitive prescription, affirming CA's dismissal.

Case Summary (G.R. No. 187633)

Petitioner and Respondents

• Petitioners assert sole ownership under Original Certificate of Title No. P-69103 (issued 1992 via Free Patent No. 021519-92-3194)
• Respondents trace title to co-heir Irene (sister of Lorenzo Tappa) by 1963 affidavit and later transfers:
– Calabazaron: two deeds of sale (1970, 1971) for 2,520 sq. m.
– Malupeng: deed of sale (1970) for 210 sq. m.
– Bacud: heir of Irene for 1,690 sq. m.

Key Dates

• 1934 onward – early possession by Tappa family
• April 29, 1963 – joint affidavit acknowledging co-ownership of land
• October 12, 1970 & August 22, 1971 – sales to Calabazaron
• November 30, 1970 – sale to Malupeng
• September 18, 1992 – issuance of OCT No. P-69103 to Spouses Tappa
• September 9, 1999 – complaint filed in RTC
• July 6, 2007 – RTC decision
• February 19, 2009 & April 30, 2009 – CA decision and resolution
• April 4, 2016 – Supreme Court judgment

Applicable Law

• 1987 Constitution (property and due process)
• Civil Code: Article 447 (quieting of title), Articles 476–477 (remedies against clouds on title), Articles 1134 & 1137 (acquisitive prescription)
• Property Registration Decree (PD 1529) – Torrens system
• Public Land Act (Commonwealth Act No. 141) – free patents

Facts

  1. Spouses Tappa allege continuous, exclusive possession since time immemorial and valid title via free patent.
  2. Respondents contend original owner Genaro Tappa’s heirs (Lorenzo and Irene) became co-owners; their shares passed respectively by inheritance and sale.
  3. Respondents have occupied and paid taxes on their portions since the 1960s–1970s.
  4. Spouses Tappa claimed the 1963 affidavit was executed under duress; respondents denied any coercion.

Ruling of the Regional Trial Court

• The RTC upheld Spouses Tappa’s title and quieted their title over the entire lot, finding no stronger evidence against OCT No. P-69103.
• It held that the free patent and Torrens registration enjoy a presumption of validity not overcome by respondents’ documents.

Ruling of the Court of Appeals

• The CA reversed and dismissed the complaint.
• On prescription: Respondents’ uninterrupted adverse possession for over 30 years ripened into ownership by extraordinary acquisitive prescription.
• On merits:
– Free patent and OCT null over private land already withdrawn from public domain by respondents’ possession.
– Spouses Tappa had neither legal nor equitable title.
– Respondents’ 1963 affidavit was a valid notarial public document; allegations of duress remained unsubstantiated.

Issues on Review

  1. Whether the Court of Appeals erred in dismissing the quieting-of-title action
  2. Whether Spouses Tappa’s Torrens title was collaterally attacked
  3. Whether respondents acquired ownership by prescription

Supreme Court Ruling

• The petition was denied and the CA decision affirmed under the 1987 Constitution.
• Quieting action: requires (a) a legal or e



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