Case Summary (G.R. No. 115381)
Background and Antecedent Facts
The case concerns a dispute over ownership of Lot No. 922 located in Butong, Cabuyao, Laguna, with an area of 1,087 square meters. Ramirez was awarded an Original Certificate of Title (OCT) No. P-4884 based on a free patent application granted in 1994. Felomino Elomina contested this, arguing possession since birth and asserting that he and his family, specifically since the time of his father, had consistently occupied the land. In 2003, following a protest he filed, the Department of Environment and Natural Resources (DENR) revoked Ramirez's patent, indicating that Ramirez had never possessed the land and that her application was based on misrepresentations.
Proceedings at the Regional Trial Court (RTC)
Felomino subsequently filed a suit in December 2005 seeking reconveyance of the title and damages, claiming he was unlawfully deprived of his property rights. Ramirez filed a motion to dismiss citing forum shopping due to an ongoing case with identical issues in the Supreme Court; however, the RTC denied this motion. In March 2008, the RTC dismissed Felomino's complaint for lack of merit, asserting that he failed to prove title and ownership to support his claim. The trial court concluded that any alleged misrepresentation did not affect Felomino's standing since he was not the real party in interest and ruled that the action had prescribed given the substantial delay in filing.
Ruling of the Regional Trial Court
The RTC found that Felomino lacked a valid cause of action and that any alleged misrepresentation by Ramirez would not benefit Felomino since he had not filed for a patent prior to Ramirez. The RTC also determined that any action for reconveyance based on alleged fraud had already prescribed, dictating a dismissal for lack of merit.
Court of Appeals' Findings
On appeal, Felomino maintained he was the real party in interest and that his cause of action had not yet prescribed because he was in possession of the property. The Court of Appeals reversed the RTC's decision in October 2011, underscoring that Felomino's family had long occupied the land and categorized Ramirez’s patent as obtained through fraud. The appellate court emphasized that an action for reconveyance resulting from fraud could be imprescriptible when the claimant is in possession and therefore found in favor of Felomino.
Motion for Reconsideration
After receiving the appellate court's decision, Ramirez filed a Motion for Reconsideration on November 3, 2011, which the Court of Appeals denied due to the late filing. The appellate court analyzed the timeline and found that Ramirez did not comply with the strict deadlines for filing a reconsideration as established in the Rules of Court.
Issues Raised and Court Findings
In her petition for certiorari, Ramirez presented a single issue regarding the appellate court's
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Case Overview
- This case involves a legal dispute between Leticia C. Ramirez (Petitioner) and Felomino Elomina (Respondent) regarding the ownership of a property in Cabuyao, Laguna.
- The Court of Appeals issued a resolution ordering the issuance of an Entry of Judgment in favor of Felomino Elomina, declaring him the lawful owner of the subject property and ordering Ramirez to reconvey the property to him.
Antecedent Facts
- On May 11, 1994, Ramirez received Original Certificate of Title (OCT) No. P-4884 for Lot No. 922, Cad-455-D, granted under Free Patent No. 043404-94-1330.
- Felomino filed a letter-protest against the patent application on July 11, 2000, claiming he was the rightful possessor since birth and asserting that both Ramirez and her predecessor, Delfin Torinos, were never in possession of the land.
- The Department of Environment and Natural Resources (DENR) conducted an investigation and subsequently canceled Ramirez's free patent on December 29, 2003, citing misrepresentations and fraud.
Legal Proceedings
- Felomino filed a lawsuit for reconveyance of title and damages against Ramirez and the Registry of Deeds on December 12, 2005, asserting his long-standing possession of the property.
- Ramirez filed a Motion to Dismiss claiming forum-shopping due to a pending case in the Supreme Court, which the trial court denied.
- In her Answer, Ramirez raised affirmative defenses, including prescription and that Felomino was not the real party-in-interest.
Ruling of the Regional Trial Court
- On March 13, 2008, the trial court dismissed Felomino's complaint, stating he failed to prove owners