G.R. No. 225929 . January 24, 2018
JOSE V. GAMBITO, PETITIONER, V. ADRIAN OSCAR Z. BACENA, RESPONDENT.

FACTS

Petitioner Jose V. Gambito filed a complaint for quieting of title against respondent Adrian Oscar Z. Bacena before the Municipal Trial Court (MTC). Gambito claimed ownership of a parcel of land in Bayombong, Nueva Vizcaya, under Transfer Certificate of Title (TCT) No. T-149954, tracing its origin to an Original Certificate of Title (OCT) issued in 1916. He alleged that Bacena surreptitiously obtained a free patent title, OCT No. P-21362, covering a portion of the same lot, thereby casting a cloud on his title. Bacena countered that Gambito’s title was derived from a void Deed of Sale, as the purported vendors were already deceased at the time of its execution. By way of counterclaim, Bacena sought the declaration of nullity of Gambito’s title and the affirmation of his own.
The MTC ruled in favor of Gambito, holding that Bacena’s challenge constituted an impermissible collateral attack on a Torrens title. On appeal, the Regional Trial Court (RTC) reversed the MTC, finding that Gambito failed to establish a valid legal or equitable interest necessary for quieting of title, as his title originated from a falsified deed. The RTC also held that Bacena’s counterclaim was a direct attack and that his title, having been possessed openly, had become indefeasible. The Court of Appeals affirmed the RTC decision.

ISSUE

Whether the Court of Appeals erred in affirming the dismissal of Gambito’s complaint and in upholding the validity of Bacena’s title and the award of damages.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals. The Court held that an action for quieting of title requires the plaintiff to have a valid legal or equitable title or interest in the property. Gambito’s claim was rooted in a title derived from a Deed of Sale executed by individuals already deceased, rendering the deed and the subsequent title void ab initio. Consequently, Gambito lacked the requisite interest to sustain his action.
The Court further ruled that laches did not bar Bacena’s claim. Laches presupposes the existence of a valid title in the plaintiff, which was absent here. Gambito’s title being void, he could not assert ownership or claim that Bacena’s action was belated. Regarding damages, the Court found no error in the award. The RTC and CA correctly determined that Gambito acted in bad faith, as he, being the notary public of a relevant will, was expected to have knowledge of Bacena’s rights over the property. His initiation of the suit despite this knowledge demonstrated a lack of honest intention. Therefore, the appellate court’s decision was in full accord with law and jurisprudence.