Case Summary (G.R. No. 167391)
Core factual background
The disputed parcels form part of the Maysilo Estate originally covered by OCT No. 994 (registered May 3, 1917). Phil‑Ville acquired the subject parcels by purchase from N. Dela Merced and Sons, Inc. (July 24, 1984) and holds a chain of titles culminating in TCT Nos. 270921–270923. Separately, an RTC order in 1996 adjudicated portions of Lot 23 to Eleuteria Rivera and led to issuance of TCT No. C‑314537 (about 14,391.54 sq.m.). A writ of possession and notice to vacate were issued against Phil‑Ville, but various appellate interventions and institutional inquiries (Senate, DOJ) questioned the titling history of OCT No. 994 and related titles.
Procedural history prior to Supreme Court review
Phil‑Ville filed a complaint for quieting of title and damages (Civil Case No. C‑507, RTC Caloocan) on June 5, 1997. The RTC (March 24, 2000) quieted Phil‑Ville’s titles (TCT Nos. 270921–270923), declared TCT No. C‑314537 (in the name of Eleuteria Rivera) null and void, and ordered cancellation and surrender of that TCT. Respondents pursued appellate remedies: multiple petitions and appeals went to the Court of Appeals and this Court, including transfer of a petition for review on certiorari to the Court of Appeals by a Supreme Court resolution (G.R. No. 142640). The Court of Appeals, in CA‑G.R. SP No. 62211, set aside the RTC judgment and dismissed Phil‑Ville’s complaint (Jan. 31, 2005), holding that the trial court lacked jurisdiction because the action effectively sought annulment of a CFI order of May 25, 1962; the CA affirmed the validity of an OCT dated April 19, 1917 in reliance on MWSS and Gonzaga precedents. The CA denied reconsideration (Mar. 15, 2005). Phil‑Ville elevated the matter by petition for review on certiorari.
Issues presented to the Supreme Court
Petitioner principally contested (1) whether the Court of Appeals acted without jurisdiction in entertaining respondents’ petition given prior appellate dismissals; (2) whether the CA erred in holding that the RTC lacked jurisdiction over the complaint for quieting of title; and (3) whether respondents were estopped from raising jurisdictional objections. The broader legal question focused on whether TCT No. C‑314537 in the name of Eleuteria Rivera constituted a cloud over Phil‑Ville’s titles.
Supreme Court’s determination on appellate jurisdiction and the CA’s cognizance
The Supreme Court found that the Court of Appeals properly assumed jurisdiction over respondents’ petition because this Court had referred the petition (G.R. No. 142640) to the CA through its September 25, 2000 resolution, the matter requiring factual determination beyond pure questions of law. The Court rejected petitioner’s submission that dismissal of an appeal (CA‑G.R. CV No. 66547) precluded the CA’s adjudication of respondents’ petition, noting that respondents had withdrawn their appeal and that the appellate court itself recognized such withdrawal.
Characterization of the action: quieting of title versus annulment of earlier order
The Court examined the complaint’s material allegations and relief sought to determine the nature of the action. It held that the plaintiff’s characterization governs and that Phil‑Ville’s pleading was essentially an action for quieting of title and declaratory relief under Rule 63, not an action to annul the CFI’s May 25, 1962 order. The Court emphasized that the nature of an action is determined by the complaint’s material allegations and the relief requested, irrespective of whether the plaintiff will ultimately obtain all of the relief sought.
Legal requisites for quieting of title and declaratory relief
The Court restated the two requisites for a successful action for quieting of title under Article 476: (1) plaintiff possesses a legal or equitable title or interest in the property; and (2) the instrument, claim, encumbrance or proceeding constituting the alleged cloud must be shown actually to be invalid or inoperative despite an appearance of validity, and must be prejudicial to the title sought to be quieted. The Court also noted that Rule 63 expressly allows actions to quiet title or remove clouds as a form of declaratory relief.
Findings on evidence and chain of title
Phil‑Ville established an evidentiary chain of title tracing transfers from OCT No. 994 (May 3, 1917) through successive holders to Phil‑Ville, including documentary proof (Deed of Absolute Sale, copies of OCT/TCTs, proyecto de particion, tax receipts, certification from the City Treasurer, and a geodetic plan). The DOJ and Senate committee reports appearing in the record supported that there is only one OCT No. 994 (May 3, 1917). Respondents failed to adduce competent proof establishing their ownership or to refute the documentary chain supporting Phil‑Ville’s titles. The RTC order that produced TCT No. C‑314537 had been set aside by the Court of Appeals in CA‑G.R. SP No. 43034.
Treatment of precedent concerning OCT No. 994 and related titles
The Court acknowledged controlling jurisprudence cited by respondents (MWSS v. CA; Heirs of Gonzaga v. CA) that treated an OCT dated April 19, 1917 as relevant; it also discussed subsequent Supreme Court treatment in Manotok Realty v. CLT (where the Court revisited earlier positions, created a Special Division of the Court of Appeals for remand proceedings, and issued definitive guidance regarding the status of OCT No. 994 and titles referencing an April 19, 1917 date). The Court further observed factual inconsistencies in respondents’ alleged hereditary link (noting ages and birth years reflected in the record) that cast doubt on the heirs’ chain of succession claimed from Maria de la Concepcion Vidal.
Overlap analysis and quasi in rem nature of quieting actions
...continue readingCase Syllabus (G.R. No. 167391)
Procedural Posture and Relief Sought
- Petition for review on certiorari under Rule 45 seeking to set aside the Court of Appeals Decision dated January 31, 2005 and Resolution dated March 15, 2005 in CA-G.R. SP No. 62211.
- Petitioner: Phil-Ville Development and Housing Corporation (Phil-Ville).
- Respondents: Maximo R. Bonifacio, Ceferino R. Bonifacio, Apolonio B. Tan, Benita B. Caina, Crispina B. Pascual, Rosalia B. de Gracia, Teresita S. Doronia, Christina B. Goco, Arsenio C. Bonifacio (in their capacity as surviving heirs of the late Eleuteria Rivera Vda. de Bonifacio), plus other named parties in lower proceedings.
- Relief originally sought in RTC Civil Case No. C-507: Quieting of title and damages; specifically, removal of alleged cloud over petitioner’s titles (TCT Nos. 270921, 270922, 270923) and declaration of invalidity/nullity of TCT No. C-314537 in the name of Eleuteria Rivera.
- Outcome sought in Supreme Court petition: Reversal of Court of Appeals decision that dismissed Phil-Ville’s complaint and denial of reconsideration.
Factual Background — Land Titles and Chain of Title
- Petitioner is registered owner of Lots 1-G-1, 1-G-2 and 1-G-3, subdivision plan Psd-1-13-006209, Caloocan City, aggregate area 8,694 sq. m., covered by TCT Nos. 270921, 270922, 270923 (Exhibits aWa, aXa, aYa).
- Prior to subdivision, those parcels were part of Lot 1-G, subdivision plan Psd-2731, under TCT No. T-148220 (Exhibit aVa).
- These parcels form part of Lot 23-A of the Maysilo Estate originally covered by Original Certificate of Title (OCT) No. 994, registered May 3, 1917, in the name of Isabel Gil de Sola as judicial administratrix of the estate of Gonzalo Tuason and 31 others (Exhibit aBa).
- Phil-Ville acquired the property by Deed of Absolute Sale from N. Dela Merced and Sons, Inc. on July 24, 1984 (Exhibit aBBa).
- Chain of titles leading to petitioner's ownership was presented in detail, showing successive registrants and registration dates culminating in T-148220 and eventually Phil-Ville (Exhibits aFa–aVa; list reproduced in the record).
Factual Background — Competing Titles and Proceedings
- On September 27, 1961, a group (including Eleuteria Rivera and others) claiming to be heirs of Maria de la Concepcion Vidal filed LRC No. 4557 in the CFI of Rizal seeking substitution on OCT No. 994 in place of Vidal; CFI granted substitution by Order dated May 25, 1962 (Exhibit aTTa).
- Petition for partition of the properties covered by OCT Nos. 982–985 and 994 was filed and docketed as Civil Case No. C-424 in CFI Rizal, Branch 12; on December 29, 1965 the CFI granted partition and appointed commissioners who failed to submit recommendation (Exhibit aVVa).
- Thirty-one years later (May 22, 1996), Eleuteria Rivera filed a Supplemental Motion in Civil Case No. C-424 for partition and segregation of portions of properties covered by OCT No. 994 (Exhibit aXXa).
- RTC Branch 120 (Judge Jaime D. Discaya), to which the case was transferred, granted the motion and in Order dated September 9, 1996 directed segregation of portions of Lots 23, 28-A-1 and 28-A-2 and ordered issuance of new certificates of title to Eleuteria Rivera (Exhibit aYYa).
- Register of Deeds of Caloocan issued TCT No. C-314537 to Eleuteria Rivera on September 12, 1996 covering a portion of Lot 23, area 14,391.54 sq. m. (Exhibit aQQa).
- Writ of possession and notice to vacate were issued December 26, 1996 and January 2, 1997 respectively, affecting Phil-Ville and others (Exhibits aBBBa, aCCCa, aDDDa).
Procedural History — Appellate Actions and Government Inquiries
- Bonifacio Shopping Center, Inc. filed CA-G.R. SP No. 43009; Court of Appeals Decision dated February 19, 1997 set aside the RTC Order and Writ of Possession (Exhibit aEEEa).
- Eleuteria Rivera died on February 22, 1997 at age 96 (Exhibit aSSa).
- Department of Justice issued Department Order No. 137 on April 23, 1997 creating a special committee to investigate issuance of OCT No. 994 and derivative titles.
- Court of Appeals in CA-G.R. SP No. 43034 (Decision April 29, 1997) granted Rosauro R. Aquino’s petition and set aside RTC Order of September 9, 1996 and the Writ of Possession (Exhibit aFFFa).
- On June 5, 1997, Phil-Ville filed Civil Case No. C-507 in RTC Caloocan Branch 122 for quieting of title and damages against surviving heirs of Eleuteria Rivera and the Register of Deeds.
- Senator Marcelo B. Fernan filed P.S. Resolution No. 1032 on October 7, 1997 directing Senate investigation into alleged irregularities in titling of Maysilo Estate.
- Caloocan RTC Decision dated March 24, 2000 ordered quieting of title in favor of Phil-Ville, declared TCT Nos. 270921–270923 valid and TCT No. C-314537 null and void, directed surrender/cancellation of TCT No. C-314537 and ordered attorney’s fees of P10,000 plus costs (Rollo pp. 143–187; fallo reproduced).
Trial Court Findings Adopted
- RTC adopted conclusions in Senate Committee Report No. 1031 (May 25, 1998) and DOJ Committee Report that there is only one OCT No. 994, that registered on May 3, 1917, and that the purported OCT No. 994 dated April 19, 1917 does not exist (Exhibit aIIIa; Exhibit aNNa).
- RTC found physical impossibility of respondents’ claim that they were heirs of Maria de la Concepcion Vidal because Maria was born around 1903 while Eleuteria Rivera was born in 1901, making Rivera older than her alleged grandmother (Rollo, p. 174; Exhibit aSSa).
- RTC found no overlapping of titles because Lot 23 (covered by TCT No. C-314537) lies far from Lot 23-A (where Phil-Ville’s lands are located), supported by survey plan (Exhibit aGGa).
Court of Appeals Ruling (CA-G.R. SP No. 62211) and Grounds
- Court of Appeals Decision dated January 31, 2005 set aside RTC judgment and dismissed Phil-Ville’s complaint.
- Reasoning: The RTC allegedly had no jurisdiction because Phil-Ville’s complaint effectively sought annulment of the CFI Order dated May 25, 1962 in LRC No. 4557 which substituted Eleuteria Rivera and others in place of Maria de la Concepcion Vidal on OCT No. 994.
- The appellate court affirmed validity of OCT No. 994 registered April 19, 1917 and relied on Supreme Court precedents Metropolitan Waterworks and Sewerage Systems v. Court of Appeals (G.R. No. 103558, Nov. 17, 1992) and Heirs of Luis J. Gonzaga v. Court of Appeals (G.R. Nos. 96259 & 96274, Sept. 3, 1996) (cited in CA ruling).
- Court of Appeals denied Phil-Ville’s motion for reconsideration in Resolution dated March 15, 2005.
Issues Presented to the Supreme Court
- Whether the Court of Appeals committed grave abuse of discretion in taking cognizance of respondents’ petition (CA-G.R. SP No. 62211), in light of prior dismissal of their appeal in CA-G.R. CV No. 66547.
- Whether the Court of Appeals committed grave abuse of discretion in declaring that the trial court had no jurisdiction over Civil Case No. C-507.
- Underlying substantive issue: whether TCT No. C-314537 in the name of Eleuteria Rivera constitutes a cloud over petitioner’s titles (TCT Nos. 270921–270923).
Petitioner’s Contentions (as presented)
- Court of Appeals acted without jurisdiction because respondents’ appeal in CA-G.R. CV No. 66547 was dismissed.
- Respondents’ petition to the Court of Appeals was defective: only Maximo Bonifacio signed verification and certification of non-forum shopping without proof of authorization to sign for others.
- Precedents (MWSS and Gonzaga) which upheld titles emanating from OCT No. 994 dat