Case Summary (G.R. No. 173140)
Key Dates and Procedural Posture
- Deed of Extrajudicial Settlement and Sale executed by Julian Cuizon: October 14, 1957.
- Reconstitution of original certificate of title covering the lot: 1980 (OCT No. RO-2431 reconstituted in names of the Cuison heirs and Gavina Ijordan).
- RTC rulings: September 2, 1997 (dismissal of MCIAA’s complaint insofar as respondents’ shares and recognition of MCIAA ownership of Julian’s 1/22 share) and March 6, 1998 (denial of reconsideration).
- CA decision affirming RTC: February 22, 2006 (motion for reconsideration denied June 15, 2006).
- Supreme Court decision on the petition: January 11, 2016.
Facts Established in the Record
Julian executed a Deed of Extrajudicial Settlement and Sale in 1957 purporting to convey Lot No. 4539 to CAA. MCIAA and its predecessors thereafter claimed continuous, adverse possession and relied on Tax Declaration No. 00387 in the name of BAT as evidence of possession. In 1980 respondents caused reconstitution of the original title (OCT No. RO-2431) in their names and maintained that they never sold or authorized Julian to sell their shares. MCIAA sued in RTC for cancellation of respondents’ title and for recognition of ownership based on the 1957 Deed and subsequent possession. At trial MCIAA presented a photocopy of the Deed and the tax declaration and a single witness; respondents filed a demurrer to evidence arguing lack of original document and that Julian lacked authority to convey co-owners’ shares.
Trial Court Findings
The RTC granted the demurrer to evidence with qualification: it found the 1957 Deed effective only as to Julian’s own 1/22 share (546 square meters) and not binding on the other co-owners for lack of their consent. The RTC further found MCIAA had not sufficiently established uninterrupted, material possession or any improvements to support adverse possession as to the respondents’ shares, and that the respondents’ Torrens registration could not be set aside on the showing made. The RTC therefore dismissed MCIAA’s complaint insofar as it sought cancellation of respondents’ certificate of title, but ordered the Register of Deeds to reflect MCIAA’s ownership of Julian’s 1/22 share.
Issues on Appeal Presented by MCIAA
MCIAA contended that the entire lot was conveyed in 1957; that respondents were aware of the sale and MCIAA’s continuous possession and thus impliedly ratified the sale or were estopped by laches; that MCIAA had proven possession sufficient for acquisitive prescription; and that the Deed’s provision treating respondents as holding the title in trust for MCIAA obliged respondents to surrender the certificate for cancellation.
Court of Appeals’ Disposition
The Court of Appeals affirmed the RTC’s findings and orders. It agreed that the Deed was void as to the co-owners’ shares for lack of their authority in Julian to effect a conveyance binding on them, but valid as to Julian’s own portion. The CA also sustained the RTC’s factual determinations on possession and the insufficiency of MCIAA’s evidence to establish adverse possession or other grounds to divest registered title holders of their Torrens certificate.
Supreme Court Ruling and Outcome
The Supreme Court denied the petition for review and affirmed the CA and RTC rulings. The Court held: (1) factual findings of the trial court, when affirmed by the CA, are final and conclusive absent exceptional circumstances — and none were shown to justify disturbing the lower courts’ factual conclusions on possession and proof; (2) under Article 1317 of the Civil Code a person cannot bind another by contracting in the latter’s name without authority; accordingly, Julian’s sale could affect only his undivided 1/22 share and not the shares of co-owners who did not consent; (3) estoppel and implied ratification doctrines did not apply to the nonconsenting co-owners because the contract was void as to their shares and there was nothing for them to ratify; and (4) acquisitive prescription could not defeat the respondents’ indefeasible Torrens title in the absence of satisfactory proof of adverse possession, since the Torrens System protects registered owners against loss of title by prescription.
Legal Reasoning — Authority to Convey and Effect of Co-owner’s Sale
The Court applied established principles that a co-owner’s unilateral disposition of common property binds only the vendor’s own undivided share. A purported sale by a co-owner of the entire thing, without authority from the other co-owners, transfers at most the seller’s share to the purchaser. Because the Deed lacked consent from the other co-heirs, it was unenforceable against them and therefore did not extinguish or transfer their registered interests.
Legal Reasoning — Estoppel, Ratification, and Laches
The Court rejected MCIAA’s contention that respondents’ long inaction constituted implied ratification or estoppel. The doctrine of estoppel applies to part
...continue readingCase Syllabus (G.R. No. 173140)
Case Citation and Panel
- Reported at 776 Phil. 222, First Division, G.R. No. 173140, promulgated January 11, 2016.
- Decision authored by Justice BERSAMIN, J.
- Concurrence by Chief Justice Sereno, and Justices Leonardo-De Castro, Perez, and Perlas-Bernabe.
- Case is an appeal by Mactan Cebu International Airport Authority (MCIAA) from the decision of the Court of Appeals (CA) affirming orders of the Regional Trial Court (RTC), Branch 53, Lapu-Lapu City.
Subject Matter and Core Legal Question
- Central legal question: Whether the subject property, Lot No. 4539, was validly conveyed in its entirety to petitioner MCIAA by an Extrajudicial Settlement and Sale executed in 1957 by co-heir Julian Cuizon, such that the respondents (co-heirs) could no longer claim their shares.
- Subsidiary questions: whether respondents impliedly ratified the sale through inaction or laches/estoppel; whether petitioner’s possession sufficed to establish acquisitive prescription; whether the Deed and supporting documentary evidence established title sufficient to cancel respondents’ Torrens title.
Antecedents and Material Facts
- On October 14, 1957, Julian Cuizon executed a Deed of Extrajudicial Settlement and Sale covering Lot No. 4539 (the subject lot) situated in Ibo, Municipality of Opon (now Lapu-Lapu City), in favor of the Civil Aeronautics Administration (CAA), predecessor-in-interest of petitioner MCIAA.
- Since 1957 and continuing thereafter, MCIAA (through CAA and later bureaus) alleged material, continuous, uninterrupted and adverse possession of the subject lot; the lot was declared for taxation purposes under Tax Declaration No. 00387 in the name of the Bureau of Air Transportation (BAT).
- The subject lot was later transferred and conveyed to MCIAA by virtue of Republic Act No. 6958.
- In 1980, respondents caused the judicial reconstitution of the original certificate of title covering the subject lot (issued by virtue of Decree No. 531167). Original Certificate of Title (OCT) No. RO-2431 of the Register of Deeds of Cebu was reconstituted for Lot No. 4539 in the names of the respondents’ predecessors-in-interest: Gavina Ijordan, and Julian, Francisca, Damasina, Marciana, Pastor, Angela, Mansueto, Bonifacia, Basilio, Moises and Florencio, all surnamed Cuison.
- Respondents asserted they had not sold their shares in the subject lot and had not authorized Julian to sell their shares to MCIAA’s predecessor-in-interest.
- MCIAA’s failure to obtain surrender of respondents’ owner’s copy of OCT No. RO-2431 led MCIAA to file a complaint in the RTC for cancellation of respondents’ title, alleging the 1957 sale to the Government and tax declaration in BAT’s name rendered respondents’ title void.
Documents and Evidence Offered
- MCIAA relied chiefly on:
- A photocopy of the Extrajudicial Settlement and Sale (the Deed) dated October 14, 1957.
- Tax Declaration No. 00387 in the name of the BAT.
- Testimony of Romeo Cueva, MCIAA’s legal assistant, identifying the Deed and Tax Declaration and asserting the lot’s use in expansion of the Mactan Export Processing Zone Authority I.
- Respondents moved for dismissal via Demurrer to Evidence, arguing:
- Under Section 3, Rule 130 of the Rules of Court, the contents of a document require the original for admissibility; MCIAA offered only a photocopy of the Deed.
- Even if the Deed were authentic, Julian lacked authority from co-heirs to convey their shares; Article 1317 of the Civil Code prohibits contracting in the name of another without authority.
- The tax declaration derived from an unenforceable sale had no probative value.
Procedural History
- RTC: MCIAA filed complaint for cancellation of title; after MCIAA presented its evidence, respondents filed a Demurrer to Evidence dated February 3, 1997.
- RTC Order dated September 2, 1997:
- Granted the demurrer with qualification: dismissed MCIAA’s complaint insofar as it pertained to the respondents’ shares in Lot No. 4539.
- Declared MCIAA owner of a 1/22 share (546 square meters) of Lot No. 4539 corresponding to Julian Cuizon’s share; directed Register of Deeds to change OCT No. RO-2431 accordingly.
- No pronouncement as to costs.
- RTC denied MCIAA’s motion for reconsideration on March 6, 1998.
- CA: In CA-G.R. CV No. 61509, the Court of Appeals affirmed the RTC orders in a decision promulgated February 22, 2006.
- CA denied MCIAA’s motion for reconsideration on June 15, 2006.
- MCIAA filed petition for review on certiorari to the Supreme Court (G.R. No. 173140).
Issues Presented on Appeal to the Supreme Court
- Whether the CA gravely erred in not recognizing that:
- Respond