Case Summary (G.R. No. 188145)
Historical Ownership and Transactions
The land in question was initially covered by TCT No. 58398, registered in the names of Spouses Nicolas and Francisca Nool and Spouses Cornelio and Bayang Nool, with a total area of 15.1441 hectares. In 1965, a portion was sold to the petitioners and Maria Zamora, leading to the cancellation of TCT No. 58398 and the issuance of TCT No. 58439, which included fractional shares for all owners involved. After further transactions, including a mortgage executed in 1980 and subsequent foreclosure, TCT No. 188252 was eventually issued to the petitioners and Spouses Jim and Liberty Baluyot.
Respondents’ Claims and Ejectment Proceedings
The respondents continued their possession of the property after the transactions, with Bayang asserting her claim as a co-owner based on inheritance. They argued that they had been in continuous and exclusive possession of the property, contending that they achieved ownership through ordinary acquisitive prescription. The petitioners initiated ejectment proceedings in 2000, alleging that respondents failed to share harvest proceeds as agreed.
Legal Proceedings and Initial Rulings
The Department of Agrarian Reform Adjudication Board (DARAB) dismissed the petitioners' case for lack of a tenancy relationship. Subsequently, the petitioners pursued recovery of possession through the Regional Trial Court (RTC). The RTC ruled in favor of the petitioners, ordering the respondents to vacate the property and pay compensation, thus recognizing the petitioners as the rightful owners based on their current titles.
Court of Appeals Decision
Upon appeal, the Court of Appeals (CA) reversed the RTC's decision, affirming that co-ownership existed despite the transactions involving the mortgage and foreclosure. The CA highlighted that the petitioners could not claim exclusive ownership based solely on registered title, as the foreclosure did not terminate the co-ownership rights of the respondents. The CA noted issues of forgery concerning the mortgage agreements, further undermining the validity of the petitioners' claims.
Supreme Court’s Ruling
The Supreme Court affirmed the CA's decision, determining that co-ownership between the petitioners and respondents persisted through the transactions involving TDB and the subsequent reacquisition of the property by the petitioners. It reiterated that the mere act of mortgaging without the consent of the co-owners does not affect their owners
...continue readingCase Syllabus (G.R. No. 188145)
Case Overview
- The case involves a petition for review on certiorari under Rule 45 of the Rules of Court, challenging the Decision dated June 19, 2008, and the Resolution dated May 26, 2009, of the Court of Appeals in CA-G.R. CV No. 89378.
- The controversy revolves around the ownership and possession of a parcel of land totaling 10.2135 hectares located in Villa Aglipay, San Jose, Tarlac, covered by Transfer Certificate of Title (TCT) No. 305862.
Background Facts
- The property was originally owned by Spouses Nicolas and Francisca Nool and Spouses Cornelio and Bayang Nool, with a total area of 15.1441 hectares.
- On May 3, 1965, a portion of their share was sold to the petitioners and Maria Zamora, resulting in the issuance of TCT No. 58439, which reflected the new shares of ownership.
- Over the years, several transactions occurred, including a Real Estate Mortgage executed in favor of Tarlac Development Bank (TDB) and subsequent foreclosures, leading to complex ownership dynamics.
Parties' Claims
- Petitioners: Spouses Primo and Juliana Inalvez argue that they are the sole owners of the property following its acquisition from TDB after foreclosure, asserting that any claims of co-ownership are invalid.
- Respondents: Bayang, Allan, and Celestino Nool claim that they are co-owners of th