G.R. No. 204131, June 04, 2018
SPOUSES JAIME AND CATHERINE BASA, ET AL., Petitioners, vs. ANGELINE LOY VDA. DE SENLY LOY, HEIRS OF ROBERT CARANTES, ET AL., Respondents.

FACTS

This case involves a 496-square meter lot in Baguio City originally owned by Busa Carantes. The property was mortgaged to respondent Angeline Loy and her husband in 1994. After foreclosure and a public auction where the Loys were the highest bidders, they consolidated ownership and obtained a writ of possession in 2006. Petitioners, several couples, filed a petition for quieting of title, claiming they had purchased portions totaling 351 square meters from respondent Robert Carantes (an heir of Busa) through deeds of sale executed in 1992 and 1993. They alleged taking possession and that the titles issued to Loy created a cloud on their ownership.
In defense, Angeline Loy asserted her rights as the foreclosure sale awardee, noting the petitioners’ sales were not annotated on the title and were either unnotarized or unconsummated due to non-payment. Robert Carantes, in his answer, alleged the sales did not materialize due to petitioners’ failure to pay fully. During trial, respondents failed to appear, leading to ex parte presentation of evidence by petitioners. Petitioners offered documentary evidence, including unnotarized deeds of sale (Exhibits A-D) and an affidavit from Robert Carantes (Exhibit E).

ISSUE

Whether the Court of Appeals erred in affirming the trial court’s dismissal of the petition for quieting of title.

RULING

The Supreme Court denied the petition and affirmed the lower courts’ rulings. The core legal logic rests on petitioners’ failure to substantiate their claim of ownership with competent evidence, a fatal defect for an action to quiet title. The trial court correctly denied the admission of Exhibits A to D, the purported deeds of sale. Exhibits A to C were mere photocopies, and the original of Exhibit D was not presented, violating the Best Evidence Rule under Section 3, Rule 130 of the Rules of Court. Petitioners did not establish any exception to justify the presentation of secondary evidence. Without the original documents, their existence and due execution could not be proven.
Furthermore, Exhibit E, the affidavit of Robert Carantes, was correctly disregarded as hearsay since Carantes was never presented as a witness to testify to its contents. Petitioners’ reliance on their possession of the property was insufficient, as possession alone does not equate to title; it could be based on lease, tolerance, or other arrangements. In an action for quieting of title, the plaintiff must prove not just a cloud on title, but their own valid title or ownership interest. Petitioners, bearing the burden of proof, failed to discharge this burden through the strength of their own evidence. Consequently, their petition could not prosper.