G.R. No. 271934 & G.R. No. 272834, November 27, 2024
HEIRS OF AQUILINO RAMOS, ET AL. AND MARILOU G. ILAGAN, ET AL., PETITIONERS, VS. PROSALITA BAGARES AND DANTON BAGARES, REPRESENTED BY PROSERFINA GALARRITA, RESPONDENTS.

FACTS

The late Basilia Galarrita-Naguita owned an unregistered parcel of land identified as Lot No. 12020 in Alubijid, Misamis Oriental. In 1995, respondents Prosalita and Danton Bagares claimed to have purchased a 3,000-square-meter portion of this lot. Subsequently, Aquilino Ramos filed a free patent application over the entire lot before the DENR. Respondents opposed this application, alleging that Aquilino submitted a tampered Deed of Sale of Unregistered Land to the PENRO by altering the Lot Number on the document. The PENRO denied Aquilino’s application. Meanwhile, petitioners Marilou Ilagan, Benjamin Galarrita, Elyer Galarrita, and Lydia Galarrita purchased portions of the subject property from Aquilino. After failed barangay conciliation, respondents filed a complaint for Declaration of Nullity of Tampered Deed of Sale. The Regional Trial Court ruled in favor of respondents, finding convincing proof that the Deed of Sale was tampered. The Court of Appeals affirmed the RTC’s decision, giving weight to the DENR’s findings and noting Aquilino’s own admission during barangay proceedings that he tampered with the document. The CA also held that the Heirs of Aquilino’s adverse possession for 26 years was insufficient for extraordinary acquisitive prescription and that the other petitioners could not be considered buyers in good faith.

ISSUE

1. Whether the Deed of Sale is null and void for having been tampered with.
2. Whether acquisitive prescription has set in favor of the Heirs of Aquilino Ramos.
3. Whether petitioners Marilou Ilagan, Benjamin Galarrita, and Elyer Galarrita are buyers in good faith.

RULING

The consolidated Petitions for Review are DENIED. The Court of Appeals’ Decision is AFFIRMED with the modification that the award of attorney’s fees is deleted.
1. On the Nullity of the Deed of Sale: The factual findings of the lower courts, affirmed by the CA, stand. The respondents presented convincing proof, corroborated by the DENR’s findings and Aquilino’s own admission during barangay conciliation, that the Deed of Sale was a tampered document. As a void document, it did not transfer any ownership rights over the subject property to Aquilino Ramos.
2. On Acquisitive Prescription: The claim of the Heirs of Aquilino that they acquired the property through extraordinary acquisitive prescription fails. Extraordinary acquisitive prescription requires uninterrupted adverse possession in the concept of an owner for 30 years. The Heirs of Aquilino were in possession for only 26 years (from 1978 until the filing of the case in 2004), which is short of the required period.
3. On Buyers in Good Faith: Petitioners Marilou Ilagan, Benjamin Galarrita, and Elyer Galarrita cannot be considered buyers in good faith. The subject property is unregistered land. A purchaser of unregistered land buys it at his own peril, and a claim of good faith offers no protection if the seller turns out to have no ownership or title to the property. Since Aquilino had no valid title to transmit, the petitioners acquired no rights from him.