Title
Phil-Ville Development and Housing Corp. vs. Bonifacio
Case
G.R. No. 167391
Decision Date
Jun 8, 2011
Phil-Ville contested heirs' claim over land, asserting invalid title derived from non-existent OCT. SC upheld Phil-Ville's ownership, nullifying heirs' title due to jurisdictional and validity issues.

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

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