GR 200349; (March, 2017) (Digest)
G.R. No. 200349 . March 6, 2017.
FE B. YABUT and NORBERTO YABUT, substituted by his heirs represented by CATHERINE Y. CASTILLO, Petitioners, vs. ROMEO ALCANTARA, substituted by his heirs represented by FLORA LLUCH ALCANTARA, Respondents.
FACTS
Respondent Romeo Alcantara filed a Complaint for Reconveyance over two lots (Lots 6509-C and 6509-D) in Pagadian City, claiming ownership by purchase from Pantaleon Suazola in 1960 and prior possession. He alleged that the original claimant, Tiburcio Ballesteros, employed fraud to register the property and later sold it to his daughter, petitioner Fe Yabut. Alcantara asserted his possession and sought to recover title.
The petitioners traced their claim to a 1927 Sales Application (SA 10279) by Tiburcio Ballesteros. A 1930 Bureau of Lands decision rejected a rival application by Barbara Andoy, upholding Ballesteros’s rights. Andoy’s heirs, the Jamisolas, later occupied portions, leading to protracted litigation. Despite a 1955 Department of Agriculture and Natural Resources order reaffirming Ballesteros’s rights, which was upheld by the Supreme Court in 1965 (G.R. No. L-17466), the Jamisolas’ successor, Suazola, sold portions to Alcantara. Ballesteros’s title was eventually issued in 1972.
ISSUE
Whether the respondents have a valid cause of action for reconveyance of the subject properties.
RULING
No. The Supreme Court reversed the Court of Appeals and dismissed the Complaint for Reconveyance. The Court held that reconveyance is a remedy for a landowner whose property was erroneously registered in another’s name. For it to prosper, the claimant must have a clear title and the registration must have been procured through fraud.
Here, the Court found that Alcantara and his predecessors-in-interest, the Jamisolas, never acquired valid title. The 1930 administrative decision and the final 1965 Supreme Court ruling in G.R. No. L-17466 conclusively established that Ballesteros had a better right to the land under his sales application. The Jamisolas’ subsequent occupation and sales were in bad faith, as they were aware of the prior and superior claim of Ballesteros. Since Alcantara derived his claim from the Jamisolas through Suazola, he merely stepped into their shoes and acquired no better rights. Consequently, Ballesteros’s subsequent registration and transfer to the petitioners were not tainted with fraud against a lawful owner. Absent a showing that the respondents had a registrable title wrongfully deprived from them by the petitioners’ fraud, the action for reconveyance must fail.
