G.R. No. 206240 , May 12, 2021
JOSEFINA Q. VILORIA, FELICITAS F. QUEJADO, HEIRS OF REMEDIOS Q. GAERLAN, NAMELY: BIENVENIDO B. GAERLAN, KATHLEEN DEANNA G. SALAYOG, KAREN G. LEWIS, BIENVENIDO GAERLAN, JR., MANUEL KING GAERLAN, AND RONALD GAERLAN, HEIRS OF BENJAMIN F. QUEJADO, NAMELY: EDNA S. QUEJADO, JONATHAN S. QUEJADO, ALLAN S. QUEJADO, AND PAMELA S. QUEJADO, HEIRS OF DEMETRIO F. QUEJADO, NAMELY: ANGELITA V. QUEJADO, KATHRINA ANGELICA Q. ESTRADA, OLGA DYAN Q. GARCIA, AND DEXTER JORDAN V. QUEJADO, PETITIONERS, VS. HEIRS OF PABLO GAETOS, NAMELY: HERMILINA G. GAETOS, HEIRS OF JUSTINIANO GAETOS, NAMELY: ZENAIDA G. ABAGAM, OFELIA G. BUNGAY, ESTRELLA G. CATBAGAN, VIRGILIA G. LABSON, REMEDIOS G. ADRIANO, ELVIE G. NAGMA, EDUVEJES G. VALDRIZ, ALFREDO Y. GAETOS, CATALINA GAETOS, BENEDICT GAETOS, JASON GAETOS AND HEIRS OF EUDOXIA GAETOS-SUBIDO AND HEIRS OF GALICANO GAETOS, ALL REPRESENTED BY MILDRED MADAYAG, RESPONDENTS.

FACTS

Petitioners, the heirs of Quejado, filed a complaint for Quieting of Title with Damages before the Regional Trial Court (RTC) of San Fernando City, La Union, claiming ownership over a 10,000-square meter lot in Taboc, San Juan, La Union. They asserted they inherited the property from their predecessor-in-interest who had openly, publicly, continuously, and peacefully possessed it in the concept of an owner for over 30 years. They alleged that the respondents, the heirs of Gaetos, surreptitiously caused the property to be surveyed, disturbing their title. The Quejados presented testimonial evidence from family members, a tenant, and a neighbor, along with documentary evidence including mortgage documents and tax declarations under their mother’s name, to support their claim of ownership and possession.
The Gaetos heirs denied the allegations, insisting their family owned the property by virtue of succession from a common ancestor before World War II. They presented evidence that the property was partitioned through a cadastral survey into several lots under the names of Gaetos family members. They also presented testimonial evidence from a tenant and a family member, cadastral maps, expropriation payment receipts, and current tax declarations to bolster their claim of ownership.
The RTC dismissed the Quejados’ complaint, finding they failed to convincingly establish possession in the concept of owners and lacked the requisite title for a quieting of title action. The Court of Appeals affirmed the RTC decision, ruling the petitioners failed to prove their legal or beneficial title over the subject property.

ISSUE

Whether the Court of Appeals committed a serious error of law in holding that the petitioners failed to prove they have either legal or beneficial title to institute the action to quiet title against the respondents.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals’ Decision. The Court held that the petitioners failed to establish the first requirement for an action for quieting of title, which is a legal or equitable title to, or interest in, the real property subject of the action. The tax declarations and mortgage documents presented by the petitioners, while indicative of possession, are not conclusive evidence of ownership. The Court emphasized that tax declarations, by themselves, do not prove title. Furthermore, the petitioners’ allegations of open, continuous, and exclusive possession were not substantiated by clear and convincing evidence. Since the petitioners failed to prove their legal or equitable title, their cause of action for quieting of title could not prosper. The Court also addressed a procedural matter, finding that the defective Verification and Certification against Forum Shopping was not fatal to the petition under the guidelines set in Altres v. Empleo, but ultimately denied the petition on substantive grounds.