Case Summary (G.R. No. 190810)
Applicable Law
The pertinent law governing the case includes the 1987 Philippine Constitution and Presidential Decree No. 1529 (Property Registration Decree), particularly the provisions on the necessity of registering deeds pertaining to unregistered land.
Factual Background
The Mocorros initiated legal action against the Dadizons to recover an area of 78 square meters of land, supporting their claim with a historical lineage of ownership traceable to Ignacia Bernal, who sold portions of land to successive owners. The land in question was originally declared for tax purposes under various tax declarations linking the Mocorros to legitimate ownership since their purchase from Brigido Caneja, Sr. in 1973.
Trial Court Decision
The Municipal Trial Court (MTC) ruled in favor of the Mocorros, confirming their right to the disputed 78-square meter lot and ordering the Dadizons to vacate the property, pay damages, and cancel their tax declarations relative to that property. The MTC found substantial evidence demonstrating the Mocorros had a better claim to the land based on their continuous possession and legitimate documentation.
Regional Trial Court Affirmation
On appeal, the Regional Trial Court (RTC) upheld the MTC’s decision, emphasizing the weight of evidence and factual findings that supported the Mocorros' claim. The RTC concluded that the MTC's judgment should be respected unless there were any significant oversights, which were not presented by the Dadizons.
Court of Appeals Ruling
The case was taken to the Court of Appeals (CA) by the Dadizons through a notice of appeal, which was subsequently dismissed for being improperly filed, as the appeal should have been via a petition for review. The CA denied the Dadizons' motion for reconsideration, affirming that due process was not followed in their appeal process.
Supreme Court Findings
The Supreme Court found the appeal of the Dadizons to be without merit due to procedural mistakes. The Court reiterated that only a petition for review filed in accordance with the Rules of Court would be an appropriate method for such appeals, particularly when addressing decisions made in appellate jurisdiction. The Court acknowledged the necessity for registering deeds of sale related to unregistered land, emphasizing that an unregistered deed does not hold validity against third parties.
Instruction on Registration
The Supreme Court also emphasized the legislative requirement under Section 113 of Presidential Decree No. 1529, which mandates that deeds of conveyance related to unregistered lands must be recorded in the appropriate re
...continue readingCase Syllabus (G.R. No. 190810)
Case Citation
- G.R. No. 159116
- Date of Decision: September 30, 2009
- Division: First Division
- Reported in: 617 Phil. 139
Parties Involved
- Petitioners: Spouses Nestor and Felicidad Dadizon
- Respondents: Spouses Dominador and Elsa Mocorro
Background and Antecedents
- The case originated from the Municipal Trial Court (MTC) of Naval, Biliran, where the Mocorros sought to recover a 78-square meter parcel of land and to cancel the Dadizons' tax declaration.
- The Mocorros' claim was traced back to Ignacia Bernal, the original owner of a 3,231-square meter property, who sold a portion to Almeda Elaba in 1946.
- Over the years, the land changed hands through several sales, leading to the issuance of various tax declarations:
- Tax Declaration No. 504 for Ignacia Bernal.
- Tax Declaration No. 1551 for Almeda Elaba covering 224 square meters.
- Tax Declaration No. 4301 for Brigido Caneja, Sr., who sold the land to the Mocorros in 1973, resulting in Tax Declaration No. 4518.
- The Mocorros later obtained Tax Declaration No. 3478 in 1979, reflecting a mortgage against the property.
Legal Proceedings
- The MTC ruled in favor of the Mocorros on December 6, 1999, asserting their superior claim to the disputed land based on their purchase from Caneja, Sr.
- The Regional Trial Court (RTC) affirmed this ruling on May 17, 2001, confirming the factual findings and conclusions of the MTC.
- The Dadizons attempted to appeal to the Court of Appeals (CA), but their appeal was dismissed on February 26, 2003, for procedural errors, specifically adopting an incorrect mode of appeal.
Key Legal Issues
- The central issue revolved a