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. Elvira Alcantara traced her ownership of the 3,887 sqm. property to her inheritance from her mother, Asuncion Alimon. Petitioners argued that respondents had extended the latter’s possession up to the land titled to Spouses Alcantara, and usurped the harvests therefrom. 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.
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.
The RTC gave more weight to the certificate of title and Tax Declarations presented by petitioners, declaring them the absolute owners of the lot and 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; 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.
Spouses Belen appealed before the CA and declared that Asuncion Alimon was not a possessor or cultivator of the subject land, a fact that voided the Free Patent issued to her, as well as the resulting OCT and TCT. The appellate court additionally held that Elvira Alcantara was not a legal heir of Asuncion Alimon. Since petitioners failed to show their legal entitlement to the lot, the CA declared respondents the owners of that property. Spouses Alcantara moved for reconsideration, but to no avail.
ISSUE: Whether or not the CA committed errors of law in concluding the legal issue of ownership in favor of respondents on the basis of their Tax Declarations and the Kasulatan ng Bilihang Tuluyan ng Lupa notwithstanding the TCT of Spouses Alcantara.
A cursory reading of the Kasulatan ng Bilihang Tuluyan ng Lupa clearly shows that the lot claimed by petitioners is not the property conveyed in the deed of sale and the Tax Declarations presented. Aside from their difference in size, the two properties have distinctive boundaries. Therefore, on the face of the documents, the CA incorrectly ruled.
The last three Tax Declarations were already registered to Spouses Belen. Indicated on the dorsal portion of these documents are the following: the parcel of land, area, and boundaries covered by the Tax Declaration. Through all of these details, we read that the exhibits presented by respondents refer to Lot No. 16931, having an area of around 4,368 square meters and delineated by metes and bounds different from those described in TCT No. T-36252. Hence, the RTC accurately ruled that the evidence of respondents “consisting of tax declarations x x x shows that what is tax declared in their names is Lot No. 16931, not Lot No. 16932.”
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 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. 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.