GR 132474; (November, 1999) (Digest)
G.R. No. 132474 November 19, 1999
RENATO CENIDO (deceased), represented by VICTORIA CENIDOSA, petitioner, vs. SPOUSES AMADEO APACIONADO and HERMINIA STA. ANA, respondents.
FACTS
Respondent spouses Amadeo Apacionado and Herminia Sta. Ana filed a complaint for Declaration of Ownership against petitioner Renato Cenido over an unregistered house and lot in Binangonan, Rizal. The spouses claimed they purchased the property from the late Bonifacio Aparato, paid off two mortgages on it, paid real estate taxes, and possessed it openly as owners. They alleged Cenido fraudulently obtained a tax declaration in his name and filed an ejectment case against them. Cenido countered that he was the illegitimate son and sole heir of Bonifacio Aparato, inheriting the property. He cited a prior Municipal Trial Court (MTC) case involving a compromise agreement among Aparato’s heirs, which he claimed recognized his ownership and in which the spouses participated. The trial court dismissed the complaint, upholding Cenido’s ownership based on the MTC compromise judgment and finding the deed of sale to the spouses defective for being unnotarized and unsigned by the vendor.
ISSUE
The core issue is whether the respondent spouses have proven their ownership of the subject property, thereby entitling them to the cancellation of the tax declaration in Cenido’s name and the declaration of their own title.
RULING
The Supreme Court reversed the Court of Appeals and reinstated the trial court’s decision, dismissing the complaint. The legal logic centered on the insufficiency of the spouses’ evidence to establish a valid transfer of ownership. The Court emphasized that for unregistered land, a contract of sale must be embodied in a public document to be valid and effective for transferring ownership. The purported deed of sale presented by the spouses was a private document, neither notarized nor signed by the alleged vendor, Bonifacio Aparato. This fatal defect rendered it incapable of conveying title. Furthermore, the Court found the spouses’ claim of purchase and payment of the mortgages unsupported by clear and convincing evidence. In contrast, Cenido’s claim of filiation and heirship, while also requiring stronger proof for full successional rights, was supported by the recognition in the MTC compromise agreement, a judicial record. The tax declaration in his name, while not conclusive proof of ownership, constituted prima facie evidence of possession. The Court held that the spouses failed to overcome the presumption of correctness accorded to this tax declaration and to substantiate their claim of a valid mode of acquisition. Consequently, they did not establish a superior right to the property, and their action for declaration of ownership and nullification of Cenido’s tax declaration necessarily failed.