Case Summary (G.R. No. 224083-84)
Applicable Law
The 1987 Philippine Constitution applies as the case decision date is notably after 1990. The pertinent laws considered in the judgment involve property rights under the Torrens system and statutes governing actions for partition, ejectment, and reconveyance, including Article 1456 of the Civil Code regarding implied trusts and the applicable prescriptive periods for filing actions.
Antecedents of the Case
The subject land was covered under Transfer Certificate of Title (TCT) No. 90516. Following Honesto Sr.'s death, a partition agreement was executed in 1973 by his surviving wife, Victoria Mariano, and his sons from his first marriage, including Romeo Mariano. This partition led to the issuance of several new titles. A subsequent series of property sales and the death of several parties significantly complicated the estate's administration. Notably, Honesto Jr., one of the original heirs, initiated an ejectment case against his half-sister, Susan Mariano, leading to escalating legal disputes regarding rights to the property.
Rulings of the Lower Courts
Initially, the Municipal Trial Court ruled favorably for Clemente Mariano, granting him possession and ordering Susan to vacate the premises. However, on appeal, the Regional Trial Court dismissed the ejectment case, citing a lack of sufficient evidence of Clemente’s ownership based on prior tolerance of Susan’s possession. In a parallel civil case for partition, the RTC ruled in favor of the petitioners, ordering collation and partition of the property based on their claims.
Court of Appeals Decision
The Court of Appeals consolidated the appeals regarding both the partition and ejectment cases and ultimately reversed the RTC rulings. The appellate court reaffirmed the validity of the 1973 partition agreement, emphasizing that the petitioners failed to institute an action to annul it within the prescribed four-year period from discovering the alleged fraud. Moreover, the court noted their inaction over 32 years indicated the application of laches, barring their claims.
Supreme Court's Ruling
Upon elevating the matter to the Supreme Court, it affirmed the Court of Appeals decision, emphasizing the principle of indefeasibility of title under the Torrens system. The Supreme Court ruled that registered ownership entitled Clemente to possession, dismissing assertions of pr
...continue readingCase Syllabus (G.R. No. 224083-84)
Background of the Case
- The case involves a dispute over a parcel of land in Barrio Bukal Poblacion, Pagbilao, Quezon, originally registered under TCT No. 90516 in the name of Honesto Mariano Sr.
- Honesto Sr. sold portions of his property, including Lots 168-C-6-A, B, C, D, E, F, G, and K, to different individuals and his son, Romeo Mariano.
- After Honesto Sr.'s death in 1973, a partition agreement was executed among his heirs, which was annotated on the mother title, leading to the issuance of new titles.
- Victoria Mariano, the second wife of Honesto Sr., sold Lot No. 168-C-6-K to spouses Clemente T. Alcala and Adoracion J. Ibanez.
Ejectment Case
- In 2005, Honesto Jr. filed an ejectment case against his half-sister, Susan Mariano, claiming legal possession of Lots 168-C-6-D and 168-C-6-E.
- Susan denied Clemente’s ownership, alleging that she was the rightful owner as an heir to Honesto Sr. and that the partition agreement was void due to forgery.
Ruling of the Municipal Trial Court (MTC)
- The MTC ruled in favor of Clemente on November 24, 2009, ordering Susan to vacate the properties and pay monthly rental and attorney’s fees.