Case Summary (G.R. No. 182737)
Relevant Facts
On January 18, 1985, the children of Pedro and Josefa Quiamco executed an Extra-Judicial Declaration of Heirs and a Deed of Donation that transferred ownership of the property at TCT No. RT-3781 to their sister Trinidad Quiamco, who accepted this donation. Subsequent to this transfer, another brother, Darius Quiamco, passed away. Trinidad allowed petitioners to occupy the property. In August 1994, the Cabucos purchased this property from Trinidad, leading to their acquisition of TCT No. 130676.
Initial Legal Actions
In 1995, the Cabucos demanded that the petitioners vacate the premises, which resulted in the filing of four complaints for illegal detainer after failed attempts at amicable settlement. The respondents argued that the petitioners' continued possession was solely due to the respondents' tolerance, while petitioners claimed ownership through an alleged prior verbal donation in 1972.
Lower Court Decisions
The Municipal Trial Court of Cebu City ruled against the petitioners, stating that their claim of a verbal donation could not override the respondents' ownership substantiated by a certificate of title. Following this decision, the Regional Trial Court affirmed the ruling, which was further upheld by the Court of Appeals.
Arguments on Certiorari
The petitioners sought relief from the Supreme Court under Rule 65, alleging grave abuse of discretion by the Court of Appeals. However, the Supreme Court noted that their remedy did not substitute for an expired appeal period. They had received notice of the Court of Appeals' resolution on January 28, 2000, which indicated that their period to appeal had lapsed before they filed for certiorari on February 21, 2000.
Legal Principles Involved
The Supreme Court reaffirmed fundamental legal principles regarding property ownership and possession. It cited the doctrine that possession does not prevail against the ownership rights of a registered title holder. The Court stated that "prescription does not run against registered land," affirming that registered titles maintain their validity against claims of adverse possession.
Final Ruling of the Court
The Supreme Court dismissed the petition, upholding the earlier decisions of the lower courts. The Court confirmed that because the petitioners failed to provide adequ
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Case Background
- The case revolves around the ownership and possession of a residential lot and house in Barrio Carreta, Cebu City, originally owned by spouses Pedro and Josefa Quiamco.
- Pedro Quiamco passed away in 1973, followed by Josefa Quiamco in 1981, leaving behind six children: Trinidad, Avelina, Amelia, Camilo, Pedro, and Darius Quiamco.
- On January 18, 1985, the Quiamco siblings executed an Extra-Judicial Declaration of Heirs and a Deed of Donation, transferring the property to their sister Trinidad Quiamco, who accepted the donation.
- Trinidad received a new title, TCT No. 93046, in her name.
- Following the death of Darius Quiamco, Trinidad allowed her brother's surviving wife, Elizabeth Quiamco, and their children (the petitioners) to occupy the property.
Transfer of Ownership and Dispute
- On August 19, 1994, Richard and Nilda Cabucos, the respondents, purchased the property from Trinidad Quiamco, resulting in TCT No. 130676 issued in their names.
- In 1995, the Cabucos demanded that the petitioners vacate the premises, but the latter refused.
- An attempt for amicable settlement through the barangay failed.
Legal Proceedings
- The Cabucos filed four complaints for illegal detainer against the petitioners in the