G.R. No. 210338 , March 17, 2021
LUIS SERRANO (DECEASED), SUBSTITUTED BY HIS HEIRS ATTY. LENITO T. SERRANO, CARMELO A. SERRANO, DIMPNA SERRANO-ARCANGEL, AND ATTY. JOSE O. CORTEZ, PETITIONERS, VS. ROSA P. ESPEJO, MANUELA P. CORPUZ, AND SALVADOR CORPUZ, RESPONDENTS.

FACTS

Respondents Rosa P. Espejo, Manuela P. Corpuz, and Salvador Corpuz filed an action for quieting of title over a 978-square meter unregistered parcel of land in Ilocos Norte (subject property). They traced their ownership to Evaristo Piedad, who had tax declarations issued in his favor from 1906 to 1983. In 1995, a tax declaration over the subject property was issued to petitioners Luis Serrano and Carmelo Serrano (the Serranos) by virtue of an Affidavit of Ownership. The Serranos subsequently sold a 678-square meter portion to Spouses Manuel and Susan Dumlao, who constructed a building thereon. The Serranos claimed they inherited the property from Estefania Serrano de Cabanos, who obtained it from Gregoria B. Cabanos via a will, and asserted their predecessors-in-interest had actual, physical, and peaceful possession adverse to Evaristo. The Regional Trial Court (RTC) dismissed the complaint, finding the Serranos’ evidence of possession and the cadastral survey showing a partition of the property into Lot 138 (978 sq.m.) and Lot 139 (963 sq.m.) credible. The Court of Appeals (CA) reversed the RTC, declaring respondents the lawful owners, nullifying the Serranos’ tax declarations and the sale to Spouses Dumlao, and awarding attorney’s fees to respondents.

ISSUE

Whether the Court of Appeals committed reversible error in granting the action for quieting of title in favor of the respondents.

RULING

Yes, the petition is meritorious. The Supreme Court reversed the CA Decision and reinstated the RTC Decision dismissing the complaint. For an action for quieting of title to prosper, the complainant must have a legal or equitable title or interest in the property, and the deed or claim casting a cloud on that title must be shown to be invalid. The Court found respondents failed to prove the first requisite. While respondents presented tax declarations in the name of Evaristo Piedad, petitioners presented contrary tax declarations in the name of the heirs of Gregoria Bonoan covering the subject property for the years 1983 and 1985-1990, and later in 1994, which were cancelled by the 1994 Affidavit leading to the Serranos’ tax declaration. The existence of these conflicting tax declarations created a cloud on the title that warranted the action. However, the RTC correctly found that respondents’ claim of possession of the entire property was contradicted by evidence, including the cadastral survey and the Serranos’ unrefuted possession since 1956 through a caretaker. The CA erred in disregarding this evidence and the implications of the cadastral survey, which indicated a partition. Consequently, respondents failed to establish a clear legal or equitable title superior to that of the petitioners, making the action for quieting of title unmeritorious.