GR 267108; (February, 2025) (Digest)

FACTS

This case involves conflicting claims over a 243.50-square meter parcel of land with improvements located at No. 20, Corregidor Street, Bago Bantay, Quezon City (Corregidor Property). The parties are siblings and heirs of Spouses Conrado Nuñez, Sr. and Maria Nuñez. Petitioners are Conrado Nuñez, Jr., Clarita Nuñez-Abraham, Celia Nuñez-Nuñez, and the heirs of Eduveges Nuñez-Alinea and Helen Nuñez-Quiozon. Respondents are Spouses Oscar Nuñez (the eldest sibling) and Norma Nuñez.
Petitioners claim the property was owned by their mother, Maria Nuñez, evidenced by a photocopy of Transfer Certificate of Title (TCT) No. 262412 and Tax Declaration (TD) No. B-090-00778. They allege the family occupied the property since the early 1960s, with Maria funding constructions thereon. In 1988, Oscar was tasked to secure a loan using the property as collateral. After Maria’s death in 1989 and upon full loan payment in 2004, petitioners discovered the title was already cancelled and a new TCT (No. RT-125152) and TDs were issued in Oscar’s name. They contend the transfer to Oscar was merely for loan purposes, with no intent to relinquish ownership, and that they are co-owners as evidenced by their shared payments for loan amortizations, insurance, and taxes.
Respondents claim Oscar is the sole owner, evidenced by TCT No. RT-125152 and corresponding TDs. They assert Oscar applied to purchase the government-owned property from the National Housing Authority (NHA, formerly PHHC) after the previous awardee failed to comply. A 1975 Compromise Agreement and a 1977 Deed of Sale were executed between Oscar and the NHA. They presented a PHHC passbook, deed of sale, and a transmittal letter for TCT No. 239466 (a predecessor title) in Oscar’s name. They also referenced a dismissed 1981 case where Maria stated in an affidavit that the lot was covered by a title in Oscar’s name.
The Regional Trial Court (RTC) ruled in favor of petitioners, declaring them co-owners. The Court of Appeals (CA) reversed the RTC, declaring Oscar as the true and absolute owner.

ISSUE

Whether the Court of Appeals erred in reversing the RTC decision and in declaring respondent Oscar Nuñez as the true and absolute owner of the Corregidor Property.

RULING

The Supreme Court DENIED the petition and AFFIRMED the Decision and Resolution of the Court of Appeals. Respondent Oscar Nuñez is declared the true and absolute owner of the property.
The Court held that respondents sufficiently established Oscar’s ownership through clear and convincing evidence. Oscar’s title, TCT No. RT-125152, is indefeasible and incontrovertible, enjoying the presumption of regularity. The evidence presented by respondents-including the 1975 Compromise Agreement with the NHA, the 1977 Deed of Sale, the PHHC passbook showing installment payments, and the transmittal letter for the predecessor title (TCT No. 239466)-constitute a clear paper trail tracing Oscar’s acquisition of the property from the NHA. The 1981 affidavit of Maria Nuñez, stating the lot was titled in Oscar’s name, further corroborates his claim.
In contrast, petitioners failed to overcome the evidentiary weight of Oscar’s title. Their claim of co-ownership based on a supposed implied trust was not substantiated by clear and convincing evidence. The documents they presented (payment schedules, contribution lists, and personal documents showing the property’s address as their own) were insufficient to prove an implied trust or to controvert Oscar’s valid title. The photocopy of TCT No. 262412 in Maria’s name was deemed unreliable, especially against the original title presented by respondents. The claim that the property was merely transferred to Oscar for loan accommodation was unproven. The act of contributing to expenses like amortizations and taxes, by itself, does not prove co-ownership but may merely indicate familial sharing of financial burdens. Therefore, petitioners failed to discharge their burden of proof to overturn the validity of Oscar’s certificate of title.