GR 102855; (November, 1992) (Digest)
G.R. No. 102855 . November 13, 1992
DIONICIA VILLANUEVA-RICAFRENTE, ROSITA V. LOYOLA, JUANITA V. RICASA and BIBIANA ANGELES-CATIPON, petitioners, vs. HONORABLE COURT OF APPEALS and FILEMON P. RUIZ, respondents.
FACTS
Petitioners filed a complaint seeking to annul the sale of two parcels of land in Barrio Sapang, Ternate, Cavite, and the corresponding certificates of title (Original Certificate of Title No. P-3746 and Transfer Certificates of Title Nos. T-242173, T-242510, and T-242645) on grounds of illegality in the execution of the deed of sale and issuance of the titles. The properties were initially sold to spouses Danilo Andra and Angela Olano, then to spouses Amado Ibañez and Esther Rafael-Ibañez, and finally to private respondent Filemon P. Ruiz. The Ibañez spouses obtained a free patent over the land in 1981, leading to the issuance of OCT No. P-33746. The title was subsequently transferred to Masuwerte Rural Bank of Bacoor, Inc. (TCT No. T-242173), re-acquired by the Ibañez spouses (TCT No. T-242510), and finally conveyed to Ruiz (TCT No. T-242645). The trial court dismissed the complaint for failure to state a cause of action, which the Court of Appeals sustained. Petitioners elevated the case via a petition for review under Rule 45.
ISSUE
Whether the complaint sufficiently states a cause of action against private respondent Filemon P. Ruiz.
RULING
No. The Supreme Court affirmed the dismissal of the complaint. The complaint failed to allege that Ruiz was aware of any defect in the title of his predecessors-in-interest or any circumstance that would put him on notice of petitioners’ adverse claim. Thus, Ruiz is deemed an innocent purchaser for value and in good faith. The complaint also lacked specific allegations that Ruiz participated in any conspiracy to unlawfully deprive petitioners of their property or committed any actionable wrong prejudicial to them. Mere allegations of transfer and assertion of possessory rights incidental to Ruiz’s title do not constitute a cause of action. Additionally, the free patent title issued in 1981 became indefeasible and incontrovertible after one year from its issuance under the Land Registration Act. The case filed in 1988 was therefore time-barred. The petition was dismissed for lack of reversible error in the Court of Appeals’ decision.