GR 123951; (January, 2000) (Digest)
G.R. No. 123951 January 10, 2000
Romeo Ranola and Nelson Ranola, petitioners, vs. Court of Appeals, Fermin B. Alforque, et al., respondents.
FACTS
The respondents are the heirs of Cesario Alforque, who owned several parcels of land in Naga, Cebu. In 1960, they executed an affidavit declaring themselves as co-owners of two specific parcels inherited from their father. In 1967, they mortgaged these two parcels to the Rural Bank of Talisay. Upon foreclosure, the bank sold the property to petitioner Nelson Ranola in 1979. The sale included a 285-square meter lot with a house. An ejectment case against an occupant resulted in a compromise, and the house was moved to an adjacent lot claimed separately by the heirs.
Subsequent cadastral surveys created a conflict. The heirs received a notification for a 495-square meter lot (Lot 2015), which they claimed as their separate inherited property, distinct from the 285-square meter lot sold to Ranola. However, Ranola’s own survey notification included this same 495-square meter area within his claimed property, designated as Lot 1102. This led the heirs to file an action for quieting of title, asserting ownership over the 495-square meter lot based on their and their predecessor’s long-term possession and tax declarations.
ISSUE
The core issue is whether the respondents have sufficiently proven their ownership over the disputed 495-square meter parcel of land, thereby entitling them to the remedy of quieting of title against the claims of the petitioners.
RULING
The Supreme Court affirmed the Court of Appeals’ decision declaring the respondents as the true owners of the 495-square meter lot. The legal logic rests on the strength of the respondents’ evidence of ownership, which was found to be more convincing and preponderant than that presented by the petitioners. The Court emphasized that in an action for quieting of title, the plaintiff must rely on the strength of his own title, not the weakness of the defendant’s.
The respondents successfully established a clear chain of possession and claim. They presented tax declarations in the name of their predecessor, Cesario Alforque, dating back to 1946, and subsequent declarations in their own names, demonstrating continuous, open, and notorious possession in the concept of an owner. Their claim was consistent and specifically identified the lot as separate from the mortgaged and foreclosed property. In contrast, the petitioners’ claim over the disputed area was anchored solely on a survey plan that erroneously encompassed the respondents’ land. The Court found that the petitioners failed to substantiate any right or title to the 495-square meter portion. The evidence showed that what Nelson Ranola validly purchased from the bank was only the 285-square meter lot previously mortgaged by the heirs. Therefore, the respondents’ title was clear and free from any cloud cast by the petitioners’ unfounded claim. The Court ordered the Bureau of Lands to revise the survey to reflect the true 285-square meter area of Ranola’s lot and to assign a new number to the respondents’ 495-square meter property.
