G.R. No. 157593 March 22, 2007
SPS. ALBERTO and JOCELYN AZANA, Petitioners, vs. CRISTOPHER LUMBO and ELIZABETH LUMBO-JIMENEZ, Respondents.

FACTS

Respondents Lumbo filed an action for quieting of title over Lot 64 in Boracay, claiming ownership by inheritance. They asserted their parents purchased an 8.0488-hectare property at a 1939 public auction, and Lot 64, designated separately in a 1976 survey due to a conflicting claim by the spouses Gregorio, was part of this larger parcel. They argued combining Lots 63 and 64 matched the boundaries and area of the auctioned property. Petitioners Azana claimed ownership as buyers in good faith from the Gregorios, who allegedly acquired the lot from Ignacio Bandiola via a 1976 deed of sale covering 3.4768 hectares, which purportedly included Lot 64.
The Regional Trial Court (RTC) ruled for the Azanas, finding respondents failed to establish the identity of the auctioned lot as including Lot 64, noting the auctioned property’s boundaries differed from those of the combined lots. The Court of Appeals (CA) reversed, declaring the Lumbos as owners, finding the combined Lots 63 and 64 matched the boundaries and area (approximately 8 hectares) of the property described in the 1939 final bill of sale.

ISSUE

Whether the Court of Appeals erred in reversing the trial court’s findings and declaring respondents as the rightful owners of Lot 64.

RULING

The Supreme Court affirmed the CA decision, ruling in favor of respondents Lumbo. The legal logic centered on the preponderance of evidence in establishing ownership for an action to quiet title. The Court, exercising its power to review conflicting factual findings between the RTC and CA, found the CA’s analysis more convincing. The RTC relied on an equiponderance of evidence, placing the burden on the plaintiffs (Lumbo) to prove their claim’s strength. However, the CA correctly found that respondents presented superior evidence.
The 1939 final bill of sale, coupled with technical descriptions and survey plans, demonstrated that the contiguous Lots 63 and 64 collectively matched the metes and bounds and total area of the property acquired at auction. In contrast, petitioners’ claim, based on a 1976 deed from Bandiola to Gregorio, was fatally defective. The deed described a 3.4768-hectare property with specific boundaries that, when plotted, did not encompass Lot 64. The land subject of that deed was a different, smaller parcel. Therefore, the Gregorios had no valid title to Lot 64 to convey to the Azanas. Since the Azanas’ title originated from a vendor with no rightful ownership, their claim as buyers in good faith could not stand. The cloud on respondents’ title was thus properly removed.