G.R. No. 159660 ; February 20, 2006
SPOUSES ANTONIO and SOLIDAD DIVINAGRACIA, ET AL., Petitioners, vs. LEONIDISA N. COMETA, ET AL., Respondents.

FACTS

Petitioners filed an action for quieting of title, declaration of nullity of extra-judicial partition, transfer certificates of title, and tax declarations concerning Lots 3116 and 3108 of the Bogo Cadastre. They claimed ownership acquired from (1) the heirs of Agustin Nuñez, the original owner who died intestate in 1924, whose properties were extrajudicially partitioned by his heirs in October 1928, and (2) from third persons who acquired the lands from Agustin’s heirs. Petitioners asserted they and their predecessors-in-interest had been in actual, peaceful, adverse, and continuous possession for over 60 years. Respondents are the sole living heirs of seven parties to the 1928 partition. In 1992-1993, they executed an “Extrajudicial Declaration of Heirs and Confirmation of a Previous Oral Partition” and an “Extrajudicial Partition,” leading to the cancellation of the original certificates of title and the issuance of new Transfer Certificates of Title (TCTs) in their names. Intervenors Alberto and Hilario Tudtud purchased several of these subdivided lots from respondents. The Regional Trial Court (RTC) ruled in favor of petitioners, declaring the 1992-1993 partition and the resulting TCTs null and void. The Court of Appeals reversed the RTC decision and dismissed the case.

ISSUE

Whether the Court of Appeals erred in reversing the RTC and dismissing the case, specifically on the grounds that: (1) the 1992-1993 extrajudicial documents were null and void; (2) the intervenor-purchasers were in bad faith; and (3) petitioners failed to prove their legal or equitable interest in the properties.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals’ decision. The Court held that to maintain an action to quiet title under Article 477 of the Civil Code, the plaintiff must have a legal or equitable title to, or interest in, the property. Petitioners claimed equitable or beneficial ownership but failed to prove it by preponderance of evidence. Of the twelve petitioners, only one testified regarding her acquisition, and the others presented no documentary or testimonial evidence other than the 1928 partition to substantiate their claims. The Court found that petitioners, who are not heirs of the parties to the 1928 partition, did not adequately demonstrate the legal mode by which they acquired the properties. Their possession alone, without proof of title or equitable interest, was insufficient to support the action. Consequently, the Court did not find merit in petitioners’ arguments regarding the nullity of the 1992-1993 partition or the bad faith of the intervenor-purchasers, as the foundational requirement of proving their own interest in the properties was not satisfied.