G.R. No. L-67582 October 29, 1987
ANTONIO VILLANUEVA and LIGAYA CABARUBIAS, petitioners, vs. INTERMEDIATE APPELLATE COURT, AMPARO MORENO DE JESUS, and EMILIO MORENO, respondents.

FACTS

Private respondents Amparo Moreno de Jesus and Emilio Moreno, heirs of the late Maximino Moreno, filed an action for quieting of title and recovery of possession against petitioners Antonio Villanueva and Ligaya Cabarubias. They alleged that since their father’s death, they and their co-heirs had been in open, continuous, and adverse possession of the disputed land. They permitted petitioners to reside on a portion of the property in 1966, but petitioners later claimed ownership over the entire lot and even sold a portion to third parties.
Petitioners, in their defense, claimed they were buying the portion they occupied from two other heirs of Moreno on installment, having paid P5,755.00 of the P8,000.00 price. They further alleged they subsequently sold this portion to Florentino Villanueva. The trial court found that petitioner Antonio Villanueva was a mere tenant and caretaker who had pleaded to purchase the land by installment but had not completed payment. It was also established that he was convicted of estafa for selling the property to Florentino Villanueva while still indebted to the heirs.

ISSUE

Whether the petitioners have acquired ownership rights over the disputed property, thereby defeating the claim of the private respondents as heirs.

RULING

The Supreme Court denied the petition and affirmed the lower courts’ rulings. The core legal logic rests on the principle that ownership cannot pass to a buyer until the full purchase price is paid under an installment sale agreement. The trial court found as a fact that petitioner Antonio Villanueva had not completed the installment payments; he remained indebted to the heirs. Consequently, title to the property never passed to him. Being a mere tenant and an installment buyer in default, he had no legal right to claim ownership or, more egregiously, to dispose of the property by selling it to another party. His act of selling constituted estafa, for which he was criminally convicted. This criminal conviction substantiates the civil finding of his lack of title. The private respondents, as pro-indiviso heirs, established their ownership through tax declarations and receipts in their names and their continuous, adverse possession. Petitioners’ possession was merely tolerated and derived from the heirs’ permission, which does not ripen into ownership. Therefore, the respondents rightfully sought the recovery of possession and the quieting of their title against the petitioners’ unfounded claims.