GR 198402; (June, 2012) (Digest)
G.R. No. 198402 ; June 13, 2012
HEIRS OF PACENCIA RACAZA, Petitioners, vs. SPOUSES FLORENCIO ABAY-ABAY, and ELEUTERIA ABAY-ABAY, Respondents.
FACTS
Respondents Spouses Abay-abay filed a complaint in 1985 to quiet title over a residential lot in Ubay, Bohol, which they acquired via a 1979 deed of sale. Among the defendants was Alexander Miel, husband of petitioner Angeles Racaza Miel, who was declared in default. The RTC ruled for the respondents in 1988, ordering the defendants to vacate. A writ of execution led to the demolition of the Miels’ house in 1991 after they failed to voluntarily vacate.
Subsequently, in 1991, petitioners, as heirs of Pacencia Racaza, filed their own complaint for quieting of title against the respondents. They claimed co-ownership of a different property under Tax Declaration No. 45C1-313, alleging actual possession since time immemorial, disturbed only by the 1985 case. They argued the demolition was unjust as only Alexander, who had no interest, was impleaded. Respondents countered by invoking the final judgment in the prior case and raised estoppel and laches due to petitioners’ failure to intervene.
ISSUE
Whether the Court of Appeals erred in affirming the dismissal of the petitioners’ complaint for quieting of title.
RULING
The Supreme Court denied the petition and affirmed the lower courts’ rulings. The legal logic rests on the conclusive nature of factual findings by the trial court, especially when affirmed by the CA. In a Rule 45 petition, only questions of law are reviewable. Petitioners’ arguments—that the land is foreshore and thus state-owned, that respondents were buyers in bad faith, and that the demolition was unconstitutional—are factual in nature. The Court found no compelling reason to re-examine the evidence, which the RTC and CA had uniformly weighed against the petitioners.
Crucially, the Court emphasized that the claim that the property is foreshore land, belonging to the public domain, cannot be pursued by the petitioners. The Republic of the Philippines is the real party-in-interest for such reversion claims. The petitioners’ inaction during the prior litigation, where petitioner Angeles Miel received the summons but did not inform her co-heirs or intervene, further undermined their claim. Their subsequent promise to vacate the property, as noted by the RTC, was deemed conduct indicative of their agreement with the prior judgment. Thus, the petition failed to present any reversible error.