GR 92557; (September, 1990) (Digest)
G.R. No. 92557 September 27, 1990
SPOUSES HADJI ALI MAMADSUAL and HADJI SALIKA MAMADSUAL, petitioners, vs. HON. COROCOY D. MOSON, SPOUSES KAGUI ABDULA MACARAPAN and KAGUI RAKMA MACARAPAN and REGISTER OF DEEDS OF COTABATO, respondents.
FACTS
Petitioners filed a complaint for “Quieting of Title to Property, Annulment of Original Certificates of Title, and Damages” with the Shari’a District Court in Cotabato City against private respondents, who held registered titles (OCT Nos. P-122 and P-138) over the disputed land. Petitioners claimed ownership through inheritance and possession since time immemorial, alleging that the respondents’ titles were fraudulently obtained. After pre-trial, the Shari’a Court directed the parties to submit sworn witness statements.
Private respondents later filed a motion to dismiss on grounds including lack of cause of action, arguing petitioners had no legal or equitable title, were improper parties for annulment, and the action, deemed one for reconveyance based on implied trust, had prescribed. The Shari’a Court granted the motion, dismissing the complaint for “lack of jurisdiction and cause of action.” It ruled that for quieting of title, a plaintiff must have legal (registered) or equitable (beneficial) title, which petitioners lacked. It further held that annulment of title was a reversion action only the Solicitor General could file, and any reconveyance action had prescribed.
ISSUE
Whether the Shari’a District Court erred in dismissing the complaint for quieting of title on the grounds of lack of cause of action and prescription.
RULING
Yes, the Supreme Court reversed the dismissal orders. The Court clarified that an action to quiet title under Article 477 of the Civil Code does not require the plaintiff to be the registered owner. “Title” can be established through other means, such as acquisitive prescription by open, continuous, and exclusive possession in the concept of an owner. Petitioners’ allegations of ownership by inheritance and possession since time immemorial, if proven, could establish a claim of title by prescription, effectively withdrawing the land from public domain and vesting private ownership. This suffices to constitute a cause of action for quieting title.
The Court also ruled that the action had not prescribed. Since petitioners alleged they were in possession of the property, the statute of limitations does not run against a possessor seeking to quiet title; the cause of action accrues only when the possessor’s title is allegedly clouded or disturbed. The trial court’s characterization of the action as one for reversion was erroneous, as a claim of prescriptive title negates the land’s status as public domain. The case was remanded to the Shari’a District Court for further proceedings on the merits.