GR 211065; (June, 2016) (Digest)
G.R. No. 211065. June 15, 2016
HEIRS OF JOSE EXTREMADURA, REPRESENTED BY ELENA H. EXTREMADURA, PETITIONERS, VS. MANUEL EXTREMADURA AND MARLON EXTREMADURA, RESPONDENTS.
FACTS
The late Jose Extremadura filed an action for quieting of title, recovery of possession, and damages against his brother Manuel and nephew Marlon. Jose claimed ownership over a parcel of land he purchased from his aunt, Corazon Extremadura, through a notarized Deed of Absolute Sale dated December 18, 1984. He alleged that he placed the land under Manuel’s care and that respondents delivered its produce to him from 1984 to 1995, but later refused to vacate or account for the harvest.
Respondents countered that they have been in open, continuous, adverse, and uninterrupted possession of the land for almost fifty years, where their house stands, thereby acquiring ownership. They asserted that Jose’s action was barred by prescription or laches. They further claimed that sharing produce with Jose was merely an act of familial generosity and that the deed of sale did not confer upon Jose the legal or beneficial title required for quieting of title.
ISSUE
Whether the Court of Appeals correctly dismissed the complaint for quieting of title.
RULING
The Supreme Court reversed the Court of Appeals and reinstated the Regional Trial Court’s decision, declaring Jose (now represented by his heirs) as the rightful owner. The Court held that an action for quieting of title requires the plaintiff to have either legal or equitable title to the property. Legal title refers to registered ownership, while equitable title is a beneficial ownership derived from a valid contract, giving the holder the right to have the legal title transferred.
The Court found that Jose sufficiently established his equitable title through the notarized Deed of Absolute Sale, a valid contract of sale where he paid the consideration and the corresponding capital gains tax. Testimony from respondent Manuel himself confirmed that the vendor, Corazon, was the owner and possessor of the land, thereby establishing her right to transfer it. The respondents’ possession was not in the concept of an owner but merely as a caretaker, as evidenced by their delivery of the land’s produce to Jose for over a decade. This act constituted recognition of Jose’s superior claim, negating any pretense of adverse possession. Consequently, Jose’s equitable title entitled him to clear the cloud cast by respondents’ unfounded claim of ownership.