GR 157449; (April, 2010) (Digest)
G.R. No. 157449 ; April 6, 2010
NEMESIO GOCO, ET AL., represented by their Attorneys-in-Fact, LYDIA G. FABIAN, ELPIDIA NAVALES and NATALIA BROTONEL, Petitioners, vs. HONORABLE COURT OF APPEALS, ATTY. HICOBLINO CATLY, LOURDES CATLY and the REGISTER OF DEEDS, CALAPAN CITY, ORIENTAL MINDORO, Respondents.
FACTS
The case involves Lot No. 2042, originally owned by Feliciano Alveyra. In 1952, the Municipality of Calapan acquired a one-half interest in the lot via a judgment award. A prior quiet title action resulted in a final Supreme Court decision subdividing the lot: Lot No. 2042-A (north) was adjudicated to Alveyra’s heirs, and Lot No. 2042-B (south) to the Municipality. The heirs’ title to Lot 2042-A was registered as TCT No. T-46154. The heirs later sold this lot to respondent spouses Hicoblino and Lourdes Catly, who subsequently obtained judicial approval to subdivide it into four new titles.
Petitioners, claiming to be lessees of the Municipality on Lot 2042-B since 1946, filed a complaint for annulment of the Catlys’ four new titles. They alleged these titles improperly included portions of the Municipality’s Lot 2042-B, prejudicing their leasehold rights. The Regional Trial Court dismissed the complaint, finding petitioners were occupying areas outside the Municipality’s titled property and thus had no cause of action against the Catlys. The Court of Appeals affirmed the dismissal.
ISSUE
Whether the petitioners have a cause of action and are the real parties in interest to file a complaint for annulment of the respondents’ certificates of title.
RULING
No. The Supreme Court affirmed the dismissal, holding petitioners lacked a cause of action and were not real parties in interest. A cause of action exists only if the plaintiff’s legal right is violated by the defendant’s correlative act or omission. Here, petitioners anchored their right to occupy the land on a lease from the Municipality of Calapan, which pertained only to Lot 2042-B. The titles they sought to annul, derived from TCT No. T-46154, covered the distinct and separate Lot 2042-A. Therefore, the Catlys’ titles did not violate any leasehold right personal to the petitioners.
Furthermore, petitioners were not the real parties in interest. A real party in interest is one who stands to be benefited or injured by the judgment. Petitioners’ allegation that the Catlys’ titles encroached upon the Municipality’s land was a recognition that the superior interest belonged to the local government, not to them as mere lessees. The right to challenge the validity of a title allegedly overlapping another’s property is vested in the owner of the encroached-upon land. Since petitioners asserted a right belonging to the Municipality, they had no standing to institute the annulment action. Their status as lessees, even with an option to purchase, did not confer the material interest required to sue.