GR 178906; (February, 2009) (Digest)
G.R. No. 178906 , February 18, 2009
ELVIRA T. ARANGOTE, petitioner, vs. SPS. MARTIN MAGLUNOB and LOURDES S. MAGLUNOB, and ROMEO SALIDO, Respondents.
FACTS
Petitioner Elvira T. Arangote is the registered owner of Lot 12897, evidenced by Original Certificate of Title (OCT) No. CLOA-1748 issued by the DAR. She acquired the property from Esperanza Maglunob-Dailisan, the grandaunt of respondents Martin Maglunob II and Romeo Salido. Esperanza inherited the lot from her uncle via a Partition Agreement. On June 9, 1986, Esperanza executed an Affidavit renouncing all her rights to the property in favor of petitioner and her husband, based on which a tax declaration was issued in their names. They built a house on the lot in 1989. In 1994, respondents entered the property and built a hollow block wall blocking the entrance to petitioner’s house. Petitioner filed a Complaint for Quieting of Title before the Municipal Circuit Trial Court (MCTC). Respondents claimed they co-owned the property with Esperanza, each holding a one-third share inherited from their common ancestor Martin Maglunob I, and that Esperanza’s Affidavit was obtained through fraud. The MCTC ruled in favor of petitioner. The Regional Trial Court (RTC) reversed the MCTC, declaring respondents and the other heirs of Martin Maglunob I as the lawful owners. The Court of Appeals affirmed the RTC decision.
ISSUE
1. Whether the RTC acted with grave abuse of discretion in declaring petitioner’s title null and void.
2. Whether the RTC acted with grave abuse of discretion in declaring the Affidavit of Quitclaim null and void.
3. Whether the RTC and the Court of Appeals acted with grave abuse of discretion in rejecting petitioner’s claim as possessor in good faith entitled to rights under Articles 448 and 546 of the Civil Code.
RULING
The Supreme Court denied the petition, affirming the decisions of the RTC and the Court of Appeals.
1. The RTC did not commit grave abuse of discretion. The attack on petitioner’s title was not a collateral attack but a direct challenge through a counterclaim in a quieting of title suit. Furthermore, the title (OCT CLOA-1748) was issued under the Comprehensive Agrarian Reform Program, and the evidence showed petitioner was not a qualified beneficiary as she was not an actual tiller or occupant of the land, making the issuance void.
2. The RTC did not commit grave abuse of discretion in declaring the Affidavit null and void. Esperanza could only validly renounce her one-third share in the property, not the entire lot, as the respondents were co-owners of the remaining two-thirds. The Affidavit was ineffective as to the shares of the respondents.
3. The RTC and the Court of Appeals correctly rejected petitioner’s claim of good faith. Petitioner and her husband were aware of respondents’ claim and the property’s history, as they were related to Esperanza and the respondents. Their knowledge of facts suggesting a flaw in Esperanza’s title precluded a finding of good faith. Therefore, they were not entitled to the rights of a possessor in good faith under Articles 448 and 546 of the Civil Code.