Case Summary (G.R. No. 223624)
Relevant Property and Background Facts
Lot No. 8467 was originally titled to Jose Badana. In 1955, Quirina Badana sold one-half (A12) portion of the lot, referred to as Lot No. 8467-B, to the late spouses Remigio Navares and Cesaria Gaviola, predecessors of respondents Navares, under a "Sale with Condition." In 1957, Severina Badana sold the other half, known as Lot No. 8467-A, to spouses Aaron Nadela and Felipa Jaca, ancestors of petitioners Tomakin.
Factual Dispute and Litigation Initiation
In 2004, respondents Navares filed a Complaint for Reconveyance and Damages against petitioners Tomakin. Respondents asserted their ownership over Lot No. 8467-B by virtue of the 1955 sale and alleged continuous possession and payment of realty taxes since then. They contended that petitioners purchased and caused the titling of Lot No. 8467-A and an alleged extension of ownership over Lot No. 8467-B through questionable means, including an Extra Judicial Settlement by a stranger to the property. Petitioners countered, asserting ownership over their half and alleging prescription and laches on the part of respondents attributable to the elapsed time since 1955.
Trial Court Ruling
The Regional Trial Court (RTC) ruled in favor of petitioners Tomakin in 2010, finding respondents Navares had not sufficiently proven ownership over Lot No. 8467-B. The RTC ordered respondents to return the title under Transfer Certificate of Title (TCT) No. 131499 to petitioners and to pay attorney’s fees and litigation expenses.
Court of Appeals Decision
On appeal, the Court of Appeals (CA) reversed and set aside the RTC ruling in 2014. The CA found that respondents Navares' possession was indeed in the concept of an owner based on the admission that most respondents lived in the property and leased portions thereof. The CA held that prescription did not bar respondents’ reconveyance claim because their possession was actual and continuous.
The CA also ruled that the "sale with condition" did not render the transfer of ownership ineffective since the condition reserved only the vendor’s right to fruits of the property during her lifetime and lacked express terms making ownership conditional. Moreover, petitioners lacked the legal standing to challenge this condition as they were not parties to the original deed, and Quirina Badana, the original vendor, did not assert any claim before her death.
Consequently, the CA declared the 1955 sale covering Lot No. 8467-B valid and the 1957 sale by Severina Badana valid only in so far as it applied to her half share (Lot No. 8467-A). The CA invalidated the titles held under TCT No. 131499 in the names of petitioners Tomakin and ordered the Register of Deeds to cancel the title and issue a new one in favor of respondents Navares.
Petitioners’ Motion for Reconsideration and Supreme Court’s Procedural History
Petitioners filed a Motion for Reconsideration with the CA, which was denied in 2016. They subsequently filed a Petition for Review on Certiorari under Rule 45 of the Rules of Court. The Supreme Court required respondents Navares to comment on the Petition, but respondents failed to file a Comment, resulting in a waiver of said right.
Issues for Resolution
The Petition raised four central issues: (1) whether the CA erred in finding respondents’ possession was in the concept of an owner; (2) whether the CA failed to recognize the indefeasibility of the Torrens title held by petitioners; (3) whether respondents had no cause of action without a prior declaration of heirship establishing their status as heirs of the original purchasers; and (4) whether respondents are guilty of laches for failing to assert their claim sooner.
Supreme Court’s Analysis: Possession in the Concept of Owner and Prescription
The Court upheld the CA’s factual finding that respondents were in actual, open, and continuous possession of the property in the concept of an owner. Citing the precedent in Spouses Alfredo v. Spouses Borras, the Court explained that prescription does not run against a plaintiff who remains in possession, as such possession grants the right to seek judicial protection upon disturbance or competing claims. The filing of the reconveyance complaint thus amounted to an assertion of ownership and the right to quiet title.
Indefeasibility of the Torrens Title and Remedy Chosen
Addressing the second issue, the Court clarified that respondents did not undertake a collateral attack on a certificate of title, which is protected under Section 48 of Presidential Decree No. 1529. Instead, they pursued the recognized remedy of reconveyance to correct the wrongful registration of the property. The Court referenced Director of Lands v. Register of Deeds, emphasizing that the proper recourse is a direct action for reconveyance or for damages, respecting the registry as conclusive.
Failure to Raise Declaration of Heirship and Procedural Bar on New Issues
On the third issue, th
...continue reading
Case Syllabus (G.R. No. 223624)
Nature of the Case and Procedural History
- This case involves a Petition for Review on Certiorari under Rule 45 of the Rules of Court contesting the Decision dated October 28, 2014, and the Resolution dated March 23, 2016, both issued by the Court of Appeals (CA).
- The CA Decision granted the appeal of the respondents, Heirs of Celestino Navares, and reversed the Regional Trial Court (RTC) Decision dated May 6, 2010, which favored the petitioners, Heirs of Leonarda Nadela Tomakin.
- The petitioners filed a motion for reconsideration before the CA, which was denied.
- The dispute concerns titling and ownership over a parcel titled Lot No. 8467, located in Inayawan, Cebu City.
Facts and Antecedent Proceedings
- The original owner of Lot No. 8467 was the late Jose Badana, who died without issue and was survived by two sisters: Quirina Badana and Severina Badana.
- The property was covered by Original Certificate of Title No. RO-2230 (O-7281).
- The respondents filed a Complaint for Reconveyance and Damages against the petitioners before the RTC on May 18, 2004.
- Respondents alleged:
- That on February 23, 1955, Quirina Badana sold one-half of Lot No. 8467 (referred to as A12 or Lot No. 8467-B) to her brother’s successors-in-interest, the late spouses Remigio Navares and Cesaria Gaviola, evidenced by a Deed of Absolute Sale with Condition.
- They inherited the portion Lot No. 8467-B and have paid realty taxes and occupied the property adversely, openly, and in the concept of ownership since 1955.
- On December 6, 1957, Severina Badana sold the other half (Lot No. 8467-A) to spouses Aaron Nadela and Felipa Jaca, predecessors-in-interest of petitioners.
- The petitioners claimed:
- They are heirs of Leonarda Tomakin.
- Severina Badana’s December 6, 1957 sale was valid and covered the entire Lot No. 8467.
- Leonarda Tomakin and Lucas Nadela executed a Deed of Partition conveying the property to Leonarda.
- They and their predecessors have exercised ownership over the property.
- Respondents are barred by prescription and laches due to the 49-year lapse since the 1955 sale.
- The RTC ruled in favor of the petitioners, ordering respondents to return TCT No. 131499 and pay attorney’s fees and litigation expenses.
- Respondents appealed to the CA.
Court of Appeals Decision
- The CA granted the appeal and reversed the RTC Decision.
- It ruled that prescription could not be sustained:
- Respondents’ complaint was not barred by prescription because of their continuous, actual possession and payment of taxes, confirmed by petitioners' own admission.
- The CA upheld the February 23, 1955 sale portion to respondents’ predecessors as valid despite the proviso on the reservation of the vendor’s right to fruits or products during her lifetime.
- The proviso was not construed as a condition that affects the transfer of