G.R. No. 201248 , March 11, 2015
LETICIA NAGUIT AQUINO, MELVIN NAGUIT, ROMMEL NAGUIT, ELMA NAGUIT TAYAG, YSSEL L. NAGUIT, ROSALINA NAGUIT AUMENTADO, RIZEL NAGUIT CUNANAN, CARIDAD NAGUIT PARAJAS, MILLIE NAGUIT FLORENDO, MARNEL NAGUIT, EDUARDO NAGUIT, JOSE NAGUIT, ZOILO NAGUIT, AND AMELIA NAGUIT DIZON, represented by YSSEL L. NAGUIT, Petitioners, vs. CESAR B. QUIAZON, AMANDA QUIAZON, JOSE B. QUIAZON AND REYNALDO B. QUIAZON, represented by JAIME B. QUIAZON, Respondents.

FACTS

Petitioners, heirs of Epifanio Makam and Severina Bautista, filed a complaint for Annulment and Quieting of Title before the RTC. They claimed ownership of a 557-square meter lot in Magalang, Pampanga, by virtue of a Deed of Sale dated April 20, 1894, and alleged open, continuous, adverse, and notorious possession for over a hundred years, including payment of real estate taxes. In June 2005, respondents demanded that petitioners vacate the property, claiming ownership under TCT No. 213777-R. Petitioners sought cancellation of respondents’ title and issuance of a new one in their favor.
Respondents, in their Answer, asserted absolute ownership under TCT No. 213777-R, derived from OCT No. RO-1138 (11376) issued pursuant to Land Registration Decree No. 122511 dated June 28, 1919, in Land Registration Case No. 5, wherein the Baluyut siblings (respondents’ predecessors) were declared owners over the opposition of Jose Makam (petitioners’ predecessor). They argued petitioners had no cause of action, the action was barred by prescription and laches, and was res judicata due to a prior dismissed case (Civil Case No. 5487).
The RTC set a preliminary hearing on affirmative defenses. Respondents presented evidence including the 1919 Decision and Decree, OCT, and TCT. Petitioners opted not to present evidence, relying solely on their complaint’s allegations. The RTC dismissed the complaint, finding petitioners’ deed invalidated by the 1919 decision, and that petitioners lacked legal or equitable title, thus failing to state a cause of action for quieting of title. The CA affirmed the RTC’s dismissal.

ISSUE

Whether the RTC and CA correctly dismissed the complaint for quieting of title based on the affirmative defenses raised in a preliminary hearing, particularly for failure to state a cause of action.

RULING

Yes, the Supreme Court affirmed the CA and RTC rulings. The Court held that a preliminary hearing on an affirmative defense, such as failure to state a cause of action, is allowed under Section 6, Rule 16 of the Rules of Court. In such a hearing, the court may consider evidence beyond the complaint’s allegations to determine if the defense is meritorious. The evidence presented by respondents, specifically the 1919 Decision and the derived Torrens titles, conclusively established that petitioners’ predecessors-in-interest were already adjudged not to be the owners of the property in a cadastral proceeding. Consequently, petitioners could not claim any legal or equitable title to the property, which is an indispensable requirement for an action to quiet title. Since petitioners failed to show any interest in the property, their complaint indeed failed to state a cause of action. The defense of res judicata was also applicable as the ownership issue had been conclusively settled in the 1919 land registration case. The Court found no reversible error in the lower courts’ decisions.