FACTS: In 2005, Spouses Alcantara filed before the RTC a Complaint against Spouses Belen for the quieting of title, reconveyance of possession, and accounting of harvest with damages. Petitioners argued that their neighbors, respondents herein, had extended the latter’s possession up to the land titled to Spouses Alcantara, and usurped the harvests therefrom.
Spouses Alcantara claimed that they were the registered owners of Lot No. 16932 — a 3,887-square-meter parcel of land planted with trees and covered by Transfer Certificate of Title (TCT) No. T-36252. Elvira Alcantara traced her ownership of the property to her inheritance from her mother, Asuncion Alimon. By virtue of an Affidavit of Self-Adjudication dated 24 March 1993, Free Patent No. (IV-5)-3535 dated 28 August 1974 and Original Certificate of Title (OCT) No. P-512 issued on 17 January 1975 were cancelled, and, in lieu thereof, TCT No. T-36252 was issued in the name of Elvira Alcantara.
In addition to the certificate of title, Spouses Alcantara submitted as evidence the Tax Declarations of the property registered to them and their predecessors-in-interest, receipts of their payments for real property taxes, and a Sketch/Special Plan of Lot No. 16932 prepared by Geodetic Engineer Augusto C. Rivera.
On the strength of a sales agreement called Kasulatan ng Bilihang Tuluyan ng Lupa, respondents countered Spouses Alcantara’s claims over the property. Spouses Belen alleged that they bought the property from its prior owners. Even though respondents did not have any certificate of title over the property, they supported their claim of ownership with various Tax Declarations under the name of their predecessors-in-interest. Spouses Belen also submitted a Sketch/Special Plan of Lot No. 16932 prepared by Geodetic Engineer Hector C. Santos.
Furthermore, Spouses Belen attacked the OCT of Asuncion Alimon. They claimed that fraud attended the issuance of a Free Patent to her, considering that the Belens had occupied the property ever since. According to respondents, they already protested her title still pending before the Community Environment and Natural Resources Office (CENRO) of the Department of Environment and Natural Resources (DENR).
In its Decision dated 9 February 2009, the RTC gave more weight to the certificate of title and Tax Declarations presented by petitioners, declaring them the absolute owners of Lot No. 16932. The trial court further dislodged the use of the Tax Declarations registered under the names of Spouses Belen and their predecessors-in-interest, because these documents did not have the technical description of the land and its boundaries; and in contrast, the TCT of Spouses Alcantara defined the subject property by metes and bounds, with a technical description approved by the Land Management Bureau.
ISSUE: WON THE CA CORRECTLY RULED ON THE VALIDITY OF TITLE OF THE PETITIONER, THE VALIDITY OF PATENT AND THE RIGHTS OF PETITIONER TO SUCCEED AS HEIRS OF THEIR PREDECESSORS.
HELD: NO. Aside from presenting a certificate of title to the claimed property, petitioners submit as evidence the Tax Declarations registered to them and to their predecessors-in-interest. These Tax Declarations, together with the certificate of title presented by petitioners, support their claims over Lot No. 16932. Therefore, the CA incorrectly disposed of the property in favor of respondents, considering the indefeasibility of the Torrens title submitted as evidence by petitioners. In Pioneer Insurance and Surety Corp. v. Heirs of Coronado, we discussed the instant legal issue as follows:
Indubitably, a certificate of title serves as evidence of an indefeasible and incontrovertible title to the property in favor of the person whose name appears therein. The real purpose of the Torrens System of land registration is to quiet title to land and put stop forever to any question as to the legality of the title.
In the same assailed ruling, the CA went beyond the contents of the TCT and concluded that its issuance was a nullity. It went on to declare the Free Patent issued to Asuncion Alimon void and ruled that Elvira Alcantara was not a lawful heir of Asuncion Alimon.
In declaring the nullity of the Free Patent, the CA held thus:
A Free Patent cannot be issued to Alimon because it cannot be issued to a person who is not a possessor or cultivator of the land or is not paying taxes that will justify segregation from the public land of the land applied for. Alimon intentionally applied for a Free Patent absent the foregoing requirements.
Noticeably, the CA failed to cite any specific exhibit on record showing that Asuncion Alimon did not possess the land when she applied for the patent. In effect, it jumped to conclusions without any sufficient basis for its premise. This form of adjudication is flawed, as no less than the Constitution mandates that a court decision must express clearly and distinctly the facts and the law on which it is based.
Anent the legal status of Elvira Alcantara, the CA stated:
On the other hand, appellee Elvira Alcantara is just a “Palake” of Alimon who had transferred the land to themselves. Appellee is not a legal heir of Alimon. Margarito Belarmino, who testified for the appellees, admitted in court during cross-examination that appellee Elvira Alcantara is just a “Palake” or adopted.
In Bagayas v. Bagayas, this Court reiterated that courts must refrain from making a declaration of heirship in an ordinary civil action because “matters relating to the rights of filiation and heirship must be ventilated in a special proceeding instituted precisely for the purpose of determining such rights.” Straightforwardly, the CA is precluded from determining the issue of filiation in a proceeding for the quieting of title and accion reivindicatoria.
While there are exceptions to this rule, none obtains in this case. There is no allegation on record that, as regards the parties, a special proceeding was instituted but was finally closed and terminated. In the proceedings before the RTC, none of the parties exhaustively presented evidence regarding the issue of filiation, save for the above-cited testimony of Margarito Belarmino. Neither did the trial court make any pronouncement as regards that issue. Given, therefore, the dearth of evidence and discussion on filiation a quo,the CA should not have adjudicated the status of Elvira Alcantara as a legitimate daughter or an adopted child in succeeding to the rights of Asuncion Alimon.
All told, we find that the CA committed an error of law in giving precedence to the Tax Declarations and irrelevant deed of sale of Spouses Belen over a Torrens title to Lot No. 16932 registered to Spouses Alcantara. The appellate court likewise erred in nullifying the title of petitioners over the realty, because it did not provide any basis for invalidating the Free Patent of Asuncion Alimon. Finally, we find fault on the part of the CA in improperly declaring Elvira Alcantara an adopted child outside the confines of a special proceeding.