Case Summary (G.R. No. 233118)
Overview of Property Dispute
At the heart of this case is a parcel of land identified as Lot 2189-B, measuring 2,181 square meters, situated in Barangay San Agustin, Iba, Zambales. The property is registered under Original Certificate of Title No. 5589 in the name of Andrea De Guia. Following Andrea's death, her heir Saturnina Apagalang executed a Deed of Purchase and Sale on January 2, 1945, selling 1,875 square meters of this property to Rafael De Guia, Natividad's spouse. Saturnina's descendants subsequently occupied the land, making improvements and paying taxes, while also conducting a subdivision of the property, which further complicated ownership claims.
Legal Proceedings and Claims
Sebastian Tamares, Saturnina's son, filed an unlawful detainer complaint against the respondents in 1999 after a lengthy period of inaction regarding the property, eventually resulting in a decision affirming the petitioner’s ownership rights based on a Torrens title. Both the MTC and RTC ruled in favor of Tamares by stating that mere possession could not destabilize a Torrens title holder's claims. After the unsuccessful attempts to recover possession, the respondents, in 2010, filed a civil complaint asserting ownership over the entire 2,181 square meters, emphasizing their long-standing possession and improvements made on the land.
Trial Court Ruling
The Regional Trial Court (RTC) ruled in favor of the respondents, deeming them as rightful owners based on the original 1945 Deed of Purchase and Sale. It ordered the petitioner to vacate the premises, remove any improvements, and recognize the respondents' ownership. The decision highlighted the established nature and documentation of the deed, asserting its validity due to notarization and long-term possession.
Court of Appeals Decision
Affirming the RTC’s ruling, the Court of Appeals (CA) concluded that the respondents established ownership via the Deed of Purchase and Sale, also acknowledging that the respondents had acquired the property through extraordinary acquisitive prescription by continuously possessing the land for more than 30 years. The CA dismissed the claims of the petitioner regarding the presumption of the Torrens title and found that the evidence presented by the respondent had surpassed the petitioner’s assertions of ownership and procedural defenses.
Supreme Court Ruling
The Supreme Court upheld the decisions of the lower courts, recognizing that although Torrens titles provide presumption of ownership, this presumption does not hold against proven competing claims of ownership through valid documentation and continuous possession. The Court noted the distinction between title and ownership, asserting
...continue readingCase Syllabus (G.R. No. 233118)
Background of the Case
- The case involves a petition for review on certiorari regarding the ownership of a parcel of land designated as Lot 2189-B, located in Brgy. San Agustin, Iba, Zambales.
- The property is covered by Original Certificate of Title No. 5589, originally registered in the name of Andrea De Guia.
- Upon Andrea’s death, her sole heir, Saturnina Apagalang, executed a Deed of Purchase and Sale in 1945, transferring ownership over a 1,875 square meter portion of the land to Rafael De Guia, who was married to Natividad De Guia.
- The heirs of Natividad and Rafael de Guia (respondents) claimed ownership based on this deed and have possessed the land since the sale.
Proceedings Below
- The Regional Trial Court (RTC) found in favor of the respondents, affirming their ownership of the subject property based on the Deed of Purchase and Sale and subsequent improvements made by them on the land.
- The RTC's decision was upheld by the Court of Appeals (CA), which also noted that the respondents had acquired the property through prescription.
Issues
- The primary legal questions involve:
- The validity of the Deed of Purchase and Sale as the basis for the respondents' claim to ownership.
- Whether respondents acquired the subject property through acquisitive prescription.
Ruling of the RTC
- The RTC ruled in favor