Case Summary (G.R. No. 246496)
Factual Background
The subject property, consisting of four parcels of unirrigated riceland totaling approximately 9,032 square meters, was originally owned and possessed by Fidel Agabas as early as 1945. Fidel and his family continuously cultivated and improved the land, which was partially mountainous terrain leveled into ricefields with various tree plantations. Tax Declaration (TD) No. 2778-B was issued in Fidel’s name in 1947 covering approximately 6,000 square meters. Subsequent subdivision in 1960 allocated portions of the land to Fidel’s children, with individual tax declarations issued to each heir.
In 2008, petitioners discovered the property was covered by a Transfer Certificate of Title (TCT) issued to respondent Corazon Arcano, derived from a free patent granted to Samuel Subagan, Corazon’s predecessor. Samuel’s free patent application allegedly contained material fraud, falsely claiming the land was unoccupied and that he cultivated it, contrary to petitioners’ continuous and open possession dating back to 1945. Respondents contended that the land was originally owned by Antonio Bistoyong, Corazon’s grandfather, who allegedly tolerated Fidel’s family’s occupation merely as a temporary privilege.
Trial Court Proceedings and Findings
The Municipal Circuit Trial Court (MCTC) ruled in favor of petitioners, finding that the action was essentially one for reconveyance as petitioners sought the return of their rightful ownership. The MCTC emphasized:
- The identity of the land was established through stipulations and corroborated by boundary descriptions in the tax declarations, as well as admissions by respondent Corazon that the property claimed by petitioners was part of her titled property.
- Petitioners and their predecessors had open, continuous, exclusive, and notorious possession of the land since 1945, supported by actual cultivation and payment of taxes.
- Respondents failed to prove that petitioners’ possession was merely tolerated; no overt acts or evidentiary specifics demonstrated permission.
- The free patent granted to Samuel was obtained through fraud and misrepresentation, as he falsely declared that the land was unoccupied and cultivated only by him.
- Discrepancies in the total area reflected in tax declarations were attributable to subsequent survey and subdivision, and typographical errors; these did not negate petitioners’ possession and ownership claims.
Consequently, the MCTC declared petitioners lawful owners and ordered respondents to reconvey the affected parcels, awarding moral damages, attorney’s fees, and costs.
Higher Courts’ Rulings
The RTC reversed the MCTC, dismissing petitioners’ case on the ground that they failed to establish the identity of the land due to conflicting boundary descriptions and the inconsistency in land area from Fidel’s original TD of 6,000 square meters compared to subdivided areas of approximately 9,032 square meters. The RTC held that without clear identity, reconveyance claims could not prosper.
The Court of Appeals affirmed the RTC decision, ruling that petitioners at most demonstrated possession of some lots within a larger titled property belonging to respondents, insufficient to prove ownership or entitlement to reconveyance. The CA also dismissed the Petition because not all petitioners signed the Verification and Certification against Forum Shopping.
Issues Before the Supreme Court
- Whether the failure of all petitioners to sign the Verification and Certification against Forum Shopping warrants dismissal.
- Whether petitioners sufficiently proved the identity of the land claimed.
- Whether petitioners have established ownership or better right entitling them to reconveyance of the subject property.
- Whether the free patent issued to Samuel Subagan was rightly granted or tainted by fraud.
Legal Analysis and Supreme Court Ruling
Verification and Certification against Forum Shopping: The Court relaxed the requirement that all petitioners must sign these documents when they share a common interest and cause of action. Since the petitioners are relatives sharing ownership over parts of the same property and raised common defenses, substantial compliance was held sufficient.
Identity of the Property: The Court found the identity of the land sufficiently established because:
- Parties stipulated during pre-trial that the subject property claimed by petitioners is the same as that covered by respondents’ title.
- Respondent Corazon admitted in testimony that the land petitioners claim is part of her titled property.
- Prior ejectment proceedings recognized the property as Lot No. 758 in the Suyo Public Land Subdivision.
- Petitioners submitted tax declarations with clear boundary descriptions and areas with minimal discrepancies explained by survey adjustments and assessor typographical errors.
Ownership and Right to Reconveyance:
- Reconveyance is an action to compel transfer of property wrongly registered to another. The requisites include proof of ownership or dominical right, fraud in defendant’s registration, non-transfer to an innocent purchaser, and timely filing of the action.
- Petitioners demonstrated long, continuous, exclusive, and notorious possession of the land since 1945, improving and cultivating it in the concept of an owner, supported by tax declarations and testimonial evidence.
- Respondents failed to prove that possession was merely tolerated; no overt acts or evidence substantiated such tolerance.
- Tax declarations coupled with actual possession bear substantial evidentiary weight of ownership.
Free Patent Validity and F
Case Syllabus (G.R. No. 246496)
Facts of the Case
- Petitioners, comprising Filomena Lazaga and heirs of Mamerto Agabas, Dominga Lucena, and Loreta Saydoquen, filed a complaint for quieting of title and reconveyance against respondents, spouses Corazon and Felias Arcano.
- The disputed land consists of four adjoining parcels of unirrigated riceland in Nalvo, Quimposa, Suyo, Ilocos Sur, each approximately 2,258 square meters, covered by separate tax declarations in the names of the petitioners.
- The land was originally owned and possessed by Fidel Agabas (father of petitioners) since 1945, who cultivated and improved the property, including levelling mountainous portions and erecting structures.
- In 1960, the property was subdivided among Fidel’s children, with tax declarations issued accordingly; they planted various crops and trees, maintaining possession without disturbance.
- In 2008, petitioners discovered that the property was covered by a certificate of title issued to Samuel Subagan through a free patent, obtained via alleged fraud stating the land was unoccupied and tilled by him, contrary to petitioners’ longstanding possession.
- The property was transferred from Samuel to respondent Corazon by voluntary land transfer, resulting in a new Transfer Certificate of Title (TCT No. VLT-197) issued to Corazon.
- Respondents instituted an ejectment suit against petitioners, which was dismissed, prompting petitioners' filing of the quieting of title and reconveyance suit.
Claims and Testimonies
- Petitioners presented testimony from neighbors corroborating exclusive cultivation and possession by Fidel and his family, negating any possession or cultivation by Samuel or respondents.
- Respondents claimed ownership stemming from respondent Corazon’s grandfather, Antonio Bistoyong, with boundaries under tax declarations inconsistent with petitioners’ claims.
- Respondent Corazon admitted petitioners’ cultivation of a portion of the land but asserted such occupation was permitted merely as tolerance by her grandfather Antonio.
- Testimony suggested Antonio declined to place the land under Fidel’s name despite Fidel’s desire, supporting tolerance claims.
Decision of the Municipal Circuit Trial Court (MCTC)
- The MCTC ruled in favor of petitioners, branding the action principally one for reconveyance.
- It held that the identity of the land was undisputed by the parties, all agreeing that the land claimed by petitioners was part of the land in respondents’ title.
- The court found valid possession since 1945 by petitioners and their predecessors, uninterrupted even after free patent issuance and transfer to respondents.
- It ruled respondents failed to prove that possession was merely tolerated; no overt acts evidencing permission were shown.
- The free patent issued to Samuel was deemed null due to fraud, as Samuel falsely declared the land unoccupied and never possessed or cultivated it.
- Discrepancies in land area were explained as the property being larger than originally indicated, corroborated by surveys and petitioners’ testimony.
- The court declared petitioners as lawful owners of the property and ordered respondents to reconvey the property with corresponding damages and attorney’s fees.
Ruling of the Regional Trial Court (RTC)
- The RTC reversed the MCTC decision and dismissed the compl