Clado Vs Spouses Limpe

CLADO-REYES, et al vs SPOUSES LIMPE
TOPIC: QUIETING OF TITLE

CONTROVERSY: 2,445-square meter portion of a lot in Guiguinto, Bulacan having a
total lot area of 20,431 square meters, more or less.
FACTS
February 1, 1995, petitioners, Claudo-Reyes, filed an action to quiet title,
reconveyance and damages against respondents, Spouses Limpe, and alleged that
they have been occupying the disputed lot since 1945 through their
predecessor-in-interest, Mamerto B. Reyes.
They claimed that during his lifetime, Mamerto had accepted a verbal promise of the
former lot owner, Felipe Garcia, to give the disputed lot to him in exchange for the
surrender of his tenancy rights as a tiller thereof.
To prove that Mamerto was a former tenant of Felipe; that during his lifetime he had
worked on the lot; and that he owned and possessed the same, petitioners presented
two documents, namely: (1) Certification 7 dated October 12, 1979 and (2)
"Pagpapatunay" dated November 17, 1982 allegedly executed by Simeon I. Garcia,
the eldest son of Felipe, attesting to such facts. Petitioners also alleged that whenever
respondents visited the lot, respondent Julius Limpe would promise to deliver the
certificate of title to them. However, sometime in October 1994, petitioners received a
letter from respondents asserting ownership over the disputed lot.
In their answer, respondents contended that they are the legal owners of the lot by
virtue of a Deed of Exchange of Real Estate and Deed of Absolute Sale executed on
July 5, 1974 and February 28, 1974, respectively, between them and Farm-Tech
Industries, Incorporated they presented TCT No. T-199627, Tax Declaration and
realty tax receipts of the lot, which were all registered and declared in their names.
RTC RULING
Trial court ruled in favor of respondents and held that the certificate of title, tax
declarations and realty tax receipts presented in court indisputably established
respondents' ownership over the lot. The certificate of title was registered in
respondents' names and the realty tax receipts showed that respondents consistently
paid the corresponding real property taxes. These pieces of evidence, said the trial
court, prevail over petitioners' allegation of an "undocumented promise" by the former
lot owner, which in itself, is ineffective or unenforceable under the law. Accordingly,
the trial court ordered petitioners to reconvey the disputed lot to respondents.
CA RULING
Court of Appeals affirmed the trial court's ruling and held that petitioners have no title
whatsoever upon which respondents' title could cast a cloud, as they were the ones
casting doubt on respondents' title.
It held that the documents allegedly executed by Simeon I. Garcia showed no indicia
that the alleged owner, Felipe Garcia, donated the disputed lot to them. It further held
that Simeon I. Garcia was not the real owner of the lot; thus, he could not make an
effective conveyance thereof. Consequently, it upheld respondents' title over the
disputed lot.
ISSUE
W/O THE [PETITIONERS] HAVE A CAUSE OF ACTION TO QUIET TITLE,
RECONVEYANCE AND DAMAGES AGAINST RESPONDENTS
HELD
To prove their case, NO. Under Articles 476 22 and 477 23 of the New Civil Code.
There are two indispensable requisites in order that an action to quiet title could
prosper: (1) that the plaintiff or complainant has a legal or an equitable title to or
interest in the real property subject of the action; and (2) that the deed, claim,
encumbrance or proceeding claimed to be casting cloud on his title must be shown
to be in fact invalid or inoperative despite its prima facie appearance of validity or
legal efficacy.
PETITIONERS CONTENTION
Cited Section 4 of Article XIII of the 1987 Constitution and Section 2 of the
Comprehensive Agrarian Reform Law. They hardly argued on the matter neither
was there positive evidence (1) that their predecessor had legal title, i.e., a
certificate of land transfer; (2) that the lot was an agricultural lot and not a
commercial one as contended by respondents; and (3) that they are qualified
beneficiaries under the Agrarian Reform Law.
The documentary evidence petitioners presented, namely, the "Certification" and
"Pagpapatunay", did not confirm their title over the disputed lot. First, original
copies of those documents were not presented in court. Second, as the appellate
court pointed out, Simeon I. Garcia, the declarant in those documents, was not
presented in court to prove the veracity of their contents. Third, even a cursory
examination of those documents would not show any transfer or intent to transfer
title or ownership of the disputed lot from the alleged owner, Felipe Garcia, to
petitioners or their predecessor-in-interest, Mamerto B. Reyes. Fourth,
petitioners did not bother to adduce evidence that Simeon I. Garcia, as the eldest
son of the late Felipe Garcia, inherited the entire lot as to effectively convey title
or ownership over the disputed lot, i.e. thru extrajudicial settlement of the estate
of the late Felipe Garcia. Accordingly, we agree that the documents allegedly
executed by Simeon I. Garcia are purely hearsay and have no probative value.
RESPONDENTS CONTENTION
Respondents presented evidence which clearly preponderates in their favor. First,
the transfer certificate of title, tax declarations and realty tax receipts were all in
their names. Second, pursuant to the Torrens System, enjoys the conclusive
presumption of validity and is the best proof of ownership of the lot. Third,
although tax declarations or realty tax receipts are not conclusive evidence of
ownership, nevertheless, they are good indicia of possession in the concept of an
owner, for no one in his right mind would be paying taxes for a property that is not
in his actual or at least constructive possession. As we previously held, such
realty tax payments constitute proof that the holder has a claim of title over the
property.
After carefully considering the arguments of the parties, as well as their
respective evidence, we unanimously agree that the petitioners were not able to
prove that they have any legal or equitable title over the disputed lot. Thus, we
find no reversible error in the assailed decisions of the courts below.

Clado Vs Spouses Limpe

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CLADO-REYES, et al vs SPOUSES LIMPE

TOPIC: QUIETING OF TITLE

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