Case Summary (G.R. No. 136021)
Nature of the Case
The case involves a Petition for Review filed by the Secuya family against Gerarda M. Vda. de Selma. The action seeks to set aside a Decision by the Court of Appeals affirming the Regional Trial Court's dismissal of the Secuya’s Complaint for Quieting of Title and Cancellation of Certificate of Title of the Respondent.
Background Facts
The Secuya family contended ownership of a parcel of land located within Lot 5679 of the Talisay-Minglanilla Friar Lands Estate, alleging that this land was originally sold and titled to Maxima Caballero, who made agreements for its partition. They claimed that upon Maxima's death, her successors failed to honor these agreements, leading to their current ownership claims.
Conversely, the Respondent, Gerarda Selma, presented her title as a legitimate owner of portions of Lot 5679, having obtained these through legitimate sales from Cesaria Caballero and subsequent inheritance.
Court of Appeals Ruling
The Court of Appeals affirmed the trial court's decision that dismissed the Secuya's claims, maintaining that they failed to establish valid title to the property in question. The appellate ruling emphasized that the Secuya family’s claims were based on an Agreement of Partition, which was found to be invalid under the Public Land Act, which forbids such arrangements within a specified time post-issuance of patent.
Parts of the Dispute
The issues before the Court included the validity of the Agreement of Partition, the nature of the purported sale to Dalmacio Secuya, and the validity of the title held by the Respondent, Gerarda Selma.
Action for Quieting of Title
The Court clarified that, to successfully bring an action for quieting of title, the plaintiffs must demonstrate legal or equitable title to the real property and prove that any claims casting doubt on their title are indeed invalid. This requirement necessitates a clear and demonstrable ownership, which the Secuya family failed to provide against the fortified title of the Respondent.
Examination of the Agreement of Partition
The purported Agreement of Partition dated January 5, 1938, was deemed not a true partition but rather a trust agreement, as ownership had not been established amongst the parties. The absence of registration for this purported agreement rendered it ineffectual against third parties, which included Gerarda Selma.
Repudiation of the Trust
The failure of Maxima Caballero's heirs to execute the terms of the agreement and the absence of indications in land records constituted a repudiation of the trust, which barred any claims that arose from it over time.
Validity of the Sale to Dalmacio Secuya
Petitioners claimed that a sale occurred between Paciencia Sabellona and Dalmacio Secuya. However, they could not present definitive evidence of this transaction, as the purported document was 'lost'. In contrast, Gerarda Selma provided legitimate and recorded documentation linking her ownership to her purchases from heirs of the original landowner.
Petitioners' Failure to Assert Ownership Rights
While the Secuya family claimed continuous possessory rights, they failed to demonstrate that they exercised any indeed diligent ownership duties, such as registering the property, paying land taxes, or otherwise protecting t
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Overview of the Case
- This case involves a Petition for Review filed by the petitioners, Benigna Secuya and others, seeking to overturn the July 30, 1998 Decision of the Court of Appeals that upheld the ruling of the Regional Trial Court (RTC) of Cebu City.
- The RTC ruled in favor of the respondent, Gerarda M. Vda. de Selma, dismissing the petitioners' action for quieting of title and ordering them to vacate the premises.
- The appellate court affirmed this decision, stating there was no error in the trial court's judgment.
Background Facts
- The petitioners claimed ownership of a disputed parcel of land, a portion of Lot 5679 of the Talisay-Minglanilla Friar Lands Estate, which they allege was originally sold to Dalmacio Secuya by Paciencia Sabellona.
- The land was previously owned by Maxima Caballero Vda. de Cariño, who entered into an Agreement of Partition with Paciencia Sabellona in 1938.
- The respondent, Gerarda Selma, acquired a larger portion of Lot 5679, including the disputed area, through valid sales in 1972 and 1975.
Petitioners' Claims
- The petitioners based their ownership claim on:
- The Agreement of Partition between Maxima Caballero and Paciencia Sabellona.
- A Deed of Confirmation of Sale executed by Ramon Sabellona, the sole heir of Pac