Case Summary (G.R. No. 181359)
Petitioners
Atty. Clemencio C. Sabitsana, Jr. (family lawyer of the Muertegui family) and his wife Ma. Rosario M. Sabitsana, who acquired the lot by notarized deed on October 17, 1991, registered February 6, 1992 (Tax Declaration No. 5327).
Respondent
Juanito F. Muertegui, who purchased the lot by unnotarized deed on September 2, 1981, possessed and cultivated it with his father and brother, and paid real property taxes from 1980–1998 (original Tax Declaration No. 1996).
Key Dates
– September 2, 1981: Unnotarized sale by Alberto García to Juanito Muertegui.
– October 17, 1991: Notarized sale by García to petitioners.
– February 6, 1992: Registration of petitioners’ deed; Tax Declaration No. 5327 issued.
– August 24, 1998: Sabitsana’s letter opposing Muertegui heirs’ land registration.
– April 11, 2000: Quieting-of-title suit filed by Juanito Muertegui.
– October 28, 2002: RTC Decision in favor of respondent.
– January 25, 2007 & January 11, 2008: CA Decision and Resolution affirming RTC.
– August 5, 2013: Supreme Court decision applying the 1987 Constitution.
Applicable Law
– 1987 Constitution (property and judicial power).
– Rule 63, Rules of Court (quieting of title jurisdiction).
– Act No. 3344, as amended (recording of instruments affecting unregistered lands).
– Civil Code (Arts. 1544, 2208 on double sale and attorney’s fees).
– RA 7691 (expanded jurisdiction of lower courts).
– Code of Professional Responsibility (lawyer’s loyalty to client).
Factual Antecedents
Alberto García sold the unregistered lot to Juanito in 1981; Juanito’s family possessed and improved the land. In 1991, unaware or disbelieving the prior sale, Atty. Sabitsana purchased the same lot from García and promptly registered his deed. Upon Domingo Sr.’s death, Muertegui heirs sought registration under the Public Land Act; Sabitsana opposed, claiming ownership. Juanito filed for quieting of title and prayed to nullify petitioners’ deed, letter and tax declaration, and for damages and attorney’s fees.
Procedural History
– RTC: Found petitioners acted in bad faith; declared 1981 deed valid and preferred, nullifying the 1991 deed and Tax Declaration No. 5327; awarded P30,000 attorney’s fees and P10,000 litigation expenses to respondent.
– CA: Held sale to Juanito voidable only (absence of marital consent), but valid without annulment; applied Art. 1544, gave preference to Juanito’s prior possession; affirmed RTC decision in toto.
– Supreme Court: Granting certiorari, reviewed jurisdiction, applicable law, good faith, registration effect, and lawyer’s duty.
Issues
- Jurisdiction of the RTC over quieting of title despite assessed value (P1,230) being within lower court limits.
- Applicability of Art. 1544 (Civil Code) vs. Act No. 3344 for unregistered land.
- Prescription, laches, estoppel against respondent.
- Justifiability of attorney’s fees and litigation expenses award.
Petitioners’ Arguments
– RTC lacked jurisdiction as assessed value did not exceed P20,000 under RA 7691.
– Art. 1544 inapplicable to unregistered land; PD 1529 governs and binds only parties to the instrument.
– Respondent delayed asserting rights (laches, estoppel, prescription).
– No bad faith; therefore attorney’s fees and litigation expenses award is unwarranted or improperly supported.
Respondent’s Arguments
– Quieting of title falls under Rule 63 and is not subject to lower court limits.
– Art. 1544 applies to double sale, emphasizing petitioners’ bad faith.
– Respondent persistently exercised rights; prior recovery suit negates laches.
– Under Civil Code Art. 2208, petitioners’ bad faith compels award of attorney’s fees and expenses.
Supreme Court Ruling
- Jurisdiction: RTC has original and exclusive jurisdiction over quieting-of-title actions under Rule 63, regardless of assessed value.
- Applicable Law: Art. 1544 does not govern unregistered land; Act No. 3344 controls recording and protects thi
Case Syllabus (G.R. No. 181359)
Procedural History
- Petition for Review on Certiorari filed before the Supreme Court assails:
- January 25, 2007 Decision of the Court of Appeals in CA-G.R. CV No. 79250 denying the appeal from RTC Naval, Biliran.
- January 11, 2008 Resolution of the Court of Appeals denying petitioners’ Motion for Reconsideration.
- Civil Case No. B-1097 for quieting of title and preliminary injunction was originally filed by respondent in the Regional Trial Court (8th Judicial Region, Branch 16, Naval, Biliran) on April 11, 2000.
- RTC rendered its Decision on October 28, 2002; motion for reconsideration was denied on December 18, 2002.
Facts
- On September 2, 1981, Alberto Garcia sold by unnotarized Deed of Sale a 7,500-sqm parcel (TD No. 1996) to Juanito F. Muertegui.
- Domingo Muertegui Sr. and Jr. took actual possession, planted coconuts and ipil-ipil, and paid real property taxes (1980–1998).
- On October 17, 1991, Garcia sold the same lot to his lawyer Atty. Clemencio C. Sabitsana, Jr. by notarized Deed of Absolute Sale; registered Feb 6, 1992; TD No. 5327 issued in Atty. Sabitsana’s name.
- Atty. Sabitsana paid taxes (1992, 1993, 1999) and introduced improvements in 1996 that were destroyed by typhoon.
- He opposed the Muertegui heirs’ application to register the lot under the Public Land Act by letter dated August 24, 1998.
- Respondent, through attorney-in-fact Domingo A. Muertegui, Jr., filed suit alleging bad-faith purchase, cloud on title, and praying to annul the 1991 deed, the August 24, 1998 letter, and TD No. 5327, and for damages, attorney’s fees, and litigation expenses.
- Petitioners counterclaimed, contesting jurisdiction, good faith acquisition, prescription, laches, and absence of marital consent in the 1981 sale.
Trial Court Ruling
- Decision dated October 28, 2002:
- Declared the September 2, 1981 Deed of Sale valid and preferred.
- Declared the October 17, 1991 Deed of Absolute Sale and TD No. 5327 void and of no legal effect.
- Ordered cancellation of TD No. 5327.
- Awarded Juanito P30,000.00 as attorney’s fees, P10,000.00 as litigation expenses, plus costs.
- Held petitioners were not buyers in good