G.R. No. 215035, May 27, 2024
JULIETA F. ENRIQUEZ, ROMEO F. ENRIQUEZ, AND TITA E. VELASCO, PETITIONERS, VS. HEIRS OF FLORENCIO F. ENRIQUEZ, REPRESENTED BY ARMANDO ENRIQUEZ, RESPONDENTS.

FACTS

The petitioners (Julieta, Romeo, and Tita) and the respondents (Heirs of Florencio) are heirs of the late Faustino W. Enriquez. Petitioners alleged that in 1948, Faustino bought three lots from Ong Yok, but the “Escritura de Venta” named his eldest son, Florencio, as the vendee. Petitioners claimed Faustino bought the lots for his children from his second marriage (the petitioners). In 1952, Florencio executed a Deed of Sale (“Escritura de Venta”) covering the lots in favor of the petitioners, and later executed an Affidavit in 1956 to rectify the omission of Tita’s name. Petitioners asserted open, continuous possession and cultivation of the lots. In 2002, petitioners discovered that a free patent and Original Certificate of Title (OCT) No. P-3,588 covering one of the lots had been issued in 1997 in the name of Florencio (respondents’ predecessor), and respondents had filed an ejectment case against them. Petitioners filed a Complaint for Declaration of Nullity of Title and Declaration of Ownership. The Regional Trial Court (RTC) ruled in favor of petitioners, declaring them the absolute owners, nullifying the free patent and OCT, and making the preliminary injunction permanent. The Court of Appeals (CA) reversed the RTC, ruling that the 1948 sale to Faustino (a Chinese citizen) was void under the 1935 Constitution, and that the documents presented by petitioners (the unsigned 1952 Escritura de Venta and the unnotarized 1956 Affidavit) were insufficient to prove ownership.

ISSUE

Whether the Court of Appeals erred in reversing the RTC’s decision which declared the petitioners as the true and absolute owners of the subject lots and nullified the free patent and title issued in the name of Florencio.

RULING

The Supreme Court REVERSED the Court of Appeals’ Decision and REINSTATED the Regional Trial Court’s Decision with MODIFICATION. The Court held that the petitioners are the true and absolute owners of the subject lots. The 1948 sale from Ong Yok to Faustino was not void. Faustino, as a Filipino citizen (having elected Philippine citizenship in 1938 after reaching the age of majority), was not disqualified from acquiring land. The Court found the 1952 Escritura de Venta and 1956 Affidavit executed by Florencio to be valid and credible evidence of the sale and conveyance of the lots to the petitioners, corroborated by testimonial evidence and the petitioners’ long period of possession. Consequently, the subject lot was no longer part of the public domain when the free patent application was filed. The issuance of Free Patent No. 097332-97-5432P and OCT No. P-3,588 in the name of Florencio was therefore void ab initio. The Court declared the petitioners as the true owners and ordered the Register of Deeds to cancel the void OCT and issue new titles in the petitioners’ names.