Case Summary (G.R. No. 243146)
Property Background
The subject property is a 6,595-square meter parcel of land located in Barrio Galilea, San Jose City, Nueva Ecija. It was part of a larger property originally covered by TCT No. NT-31597 (11472) that included multiple co-owners, among them Francisco Velasco. Following the subdivision of the original property, TCT No. 15102 was issued in favor of the respondent and two others, subsequent to an extrajudicial partition that was contested by the petitioners who claimed it was executed under false pretenses, notably involving the deceased Francisco Velasco.
Preliminary Legal Proceedings
On July 16, 2010, the respondent filed a complaint for recovery of possession against the petitioners before the Municipal Trial Court in Cities (MTCC), alleging unlawful detainer and asserting her ownership based on TCT No. 15102. The respondent maintained that her title was valid and that she had previously restored possession of the property in a separate case. The petitioners, on their part, contested the validity of the respondent's title, claiming it was based on a falsified extrajudicial partition that fraudulently included the deceased Francisco.
Rulings of Lower Courts
The MTCC initially ruled in favor of the respondent, ordering the removal of the petitioners’ structures and granting her damages. This decision was subsequently appealed to the Regional Trial Court (RTC) which affirmed the MTCC's decision, upholding the validity of the respondent's title and denying any claims by the petitioners as collateral attacks that could not be the basis of possession disputes. The petitioners then escalated the matter to the Court of Appeals (CA), which likewise upheld the RTC's decision, ruling that TCT No. 15102 was conclusive evidence of the respondent’s ownership and that the counterclaims by the petitioners were improper.
Supreme Court’s Review and Findings
Upon review, the Supreme Court identified significant misapprehensions in the factual findings of the lower courts, particularly regarding the validity of the extrajudicial partition. The Court highlighted the critical fact that the document in question was purportedly signed by Francisco Velasco, who had died ten years prior to its execution, therefore rendering the agreement void. It ruled that the petitioners’ challenge of the title could indeed be treated as a direct attack due to the circumstances surrounding the execution of the extrajudicial partition.
Nullification of Title and Remand for Partition
The Supreme Court declared TCT No. 15102 as null and void, having been issued based on a falsified extrajudicial partition. Consequen
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Case Overview
- The petitioners, consisting of multiple individuals and spouses, seek to reverse the Court of Appeals' decision that affirmed a lower court's ruling ordering them to vacate a parcel of land owned by the respondent, Rebecca Magpale.
- This case revolves around issues of property ownership, possession rights, and the validity of a title issued based on an alleged falsified extrajudicial partition.
Parties Involved
- Petitioners: Amor Velasco, Spouses George Velasco, Mrs. Nolfe Velasco, and numerous other individuals and spouses who claim possession of the disputed property through their deceased father, Francisco Velasco.
- Respondent: Rebecca Magpale, represented by her children, who claims ownership of the property as the registered owner under Transfer Certificate of Title (TCT) No. 15102.
Background and Context
- The subject property is a 6,595 square meter parcel of land located in Barrio Galilea, San Jose City, Nueva Ecija, previously covered by TCT No. NT-31597 (11472).
- The original property was co-owned by several individuals, including Francisco Velasco, who passed away in 1982. Following his death, an extrajudicial partition was executed in 1992, which the petitioners allege involved a falsified signature of Francisco.
- The respondent's title, TCT No. 15102, was then issued based on this partition.