G.R. No. 133345 & No. 133324; March 9, 2000
JOSEFA CH. MAESTRADO, as substituted by her daughter LOURDES MAESTRADO-LAVIÑA and CARMEN CH. ABAYA, petitioners, vs. THE HONORABLE COURT OF APPEALS, Ninth Division and JESUS C. ROA, JR., RAMON P. CHAVES and NATIVIDAD S. SANTOS, respondents.

FACTS

The consolidated petitions involve the status of Lot No. 5872, registered in the names of the deceased spouses Ramon and Rosario Chaves. Following their intestate deaths, their heirs initiated settlement and partition proceedings. A 1956 decision approved a project of partition, but the official records of the case were missing. In the actual partition carried out, Lot No. 5872 was delivered to petitioners Josefa Maestrado and Carmen Abaya, who have possessed it since. However, this lot was omitted from the formal inventory, project of partition, and the court order.
In 1977, after discovering the omission, petitioners obtained notarized quitclaims from several co-heirs, confirming the lot’s conveyance to them. Years later, respondents, heirs of other co-owners, challenged these quitclaims, alleging their predecessors signed due to mistake, misrepresentation, or undue influence. They filed an action for partition, claiming the lot remained common property. The trial court and Court of Appeals ruled for respondents, declaring the lot as undivided co-ownership and ordering its partition.

ISSUE

The core issue is whether Lot No. 5872 remains common property of all heirs, requiring partition, or whether ownership was validly transferred to the petitioners through the 1977 quitclaims, thereby vesting in them a title that can be quieted.

RULING

The Supreme Court reversed the Court of Appeals and ruled in favor of the petitioners. The legal logic proceeds from the nature of the action and the validity of the quitclaims. An action for quieting of title is proper when the plaintiff has a legal or equitable title to the property and the defendant’s claim is clouding that title. Here, petitioners’ possession since the 1956 actual partition, coupled with the 1977 notarized quitclaims executed by their co-heirs, established a prima facie claim of ownership. The quitclaims constituted clear acts of adjudication and transfer of the heirs’ interests in the specific lot to the petitioners.
The Court found respondents’ allegations of vitiated consent—through mistake, fraud, or undue influence—unsubstantiated by clear and convincing evidence. A notarized document carries the presumption of regularity, and the burden to overthrow this presumption lies with the party challenging it. Respondents’ claims, such as signing out of “respect” or due to a lawyer’s alleged betrayal, were deemed insufficient to prove the specific, serious fraud or mistake required by law to annul a contract. Consequently, the quitclaims effectively segregated Lot No. 5872 from the mass of the estate and vested exclusive ownership in the petitioners. Therefore, the lot was no longer held in common, and the action for partition was improper. The proper remedy for petitioners was an action to quiet title, which the Supreme Court granted, declaring their ownership and ordering the cancellation of the cloud created by respondents’ adverse claim.