Title
Supreme Court
Heirs of Tiro vs. Philippine Estates Corp.
Case
G.R. No. 170528
Decision Date
Aug 26, 2008
Heirs of Tiro contested ownership of land in Marigondon, alleging fraudulent transfer by non-heir Maxima Ochea. Respondent, an innocent purchaser, acquired title via valid transfers. SC upheld respondent's title, citing good faith, laches, and petitioners' failure to prove filiation or fraud.

Case Summary (G.R. No. 170528)

Background of the Case

Petitioners filed a Complaint for Quieting of Title against respondent, asserting ownership of the disputed property based on Original Certificate of Title (OCT) No. RO-1121, which had been registered in the names of Julian and Pedro Tiro. Petitioners claimed to have been in continuous possession of the land until 1995, when they encountered another party claiming ownership. However, upon reviewing land registries, they discovered that OCT No. RO-1121 was cancelled in 1969, following which multiple transfers occurred, leading to the current registration of the property in the name of respondent under Transfer Certificate of Title (TCT) No. 35672.

Claims of Ownership and Historical Context

The cancellation of OCT No. RO-1121 was attributed to a document executed by Maxima Ochea, who purported to be the sole heir of the Tiros. Petitioners contested the legitimacy of Ochea's claim, stating that she was not related to the original owners and thus had no authority to cause the property transfer. They presented testimonies but lacked documentary evidence to substantiate their claims of heirship.

Respondent’s Defense

The respondent defended its ownership by establishing a chain of title beginning with the purchase of the land from its immediate predecessor, Pacific Rehouse Corporation. Respondent argued that all transfers were valid and transactions were made in good faith, asserting that no legal impediment existed from the time the property was transferred to Ochea and subsequently through the subsequent owners to respondent.

Ruling of the Regional Trial Court

On April 16, 2002, the Regional Trial Court (RTC) dismissed the petitioners' complaint. The RTC ruled that the claimants did not sufficiently prove their lineage to Julian and Pedro Tiro, and the alleged continuous possession of the disputed property was negated by the MTC's decision in a prior case, which favored the Spouses Velayo as the lawful possessors. Furthermore, the RTC indicated that the petitioners' claims were prescribed, considering the lapse of over ten years from the cancellation of their title.

Appeal to the Court of Appeals

Subsequently, the petitioners appealed to the Court of Appeals, which, on July 1, 2005, upheld the RTC's decision. The appellate court found that the petitioners failed to establish their claim of heirship adequately and recognized the legitimacy of the title held by the respondent. The court indicated that regardless of potential fraud in earlier transfers, if a subsequent purchaser had acquired the property in good faith, their title remained valid.

Supreme Court's Decision

The petitioners’ appeal to the Supreme Court reiterated their arguments regarding Ochea's invalid claim and the resulting fraudulent transfers. The Supreme Court concluded that the arguments were without merit, reinforcing the principle that once established, a titl

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