Thursday, March 4, 2021

DIGEST/KRIZABEL MARTINEZ/ MANANQUIL vs MOICO

 

G.R. No. 180076               November 21, 2012

DIONISIO MANANQUIL, LAUDENCIA MANANQUIL-VILLAMOR, ESTANISLAO MANANQUIL, and DIANITA MANANQUIL-RABINO, represented by OTILLO RABINO, Petitioners,
vs.
ROBERTO MOICO, Respondent.

 

FACTS

In 1991, Iluminardo and Prescilla Mananquil died without issue, but it turned out that Prescilla had a child by a previous marriage – namely Eulogio. After the spouses’ death, the Mananquil heirs executed an Extrajudicial Settlement Among Heirs and adjudicated ownership over Lots 18 and 19. They took possession of Lots 18 and 19 and leased them out to third parties.

The Mananquil heirs discovered that in 1997, Eulogio and two others, Eulogio Baltazar Maypa and Brenda Luminugue, on the claim that they are surviving heirs of Iluminardo and Prescilla, had executed an Extrajudicial Settlement of Estate with Waiver of Rights and Sale, and a Deed of Absolute Sale in favor of Roberto Moico.

Moico began evicting the Mananquils’ tenants and demolishing the structures they built on Lots 18 and 19. In June, the Mananquils instituted a case for quieting of title and injunctive relief.

The RTC issued a TRO, thus suspending eviction and demolition. After trial on the merits, a Decision was rendered in favor of the Mananquils.

Moico appealed to the CA, which reversed the trial court.

The CA noted that Lots 18 and 19 must still belong to the NHA, in the absence of proof that Iluminardo and Prescilla have completed installment payments thereon, or were awarded titles to the lots. And if the couple disposed of these lots even before title could be issued in their name, then they may have been guilty of violating conditions of the government grant, thus disqualifying them from the NHA program. Consequently, there is no right in respect to these properties that the Mananquils may succeed to. If this is the case, then no suit for quieting of title could prosper, for lack of legal or equitable title to or interest in Lots 18 and 19.

 

ISSUE

Whether or not the CA committed a grievous error in construing the provisions of articles 476 and 477 of the civil code against petitioners notwithstanding the positive circumstances obtaining in this case pointing to the propriety of the cause of action for quieting of title

 

RULING

No. 

An action for quieting of title is essentially a common law remedy grounded on equity. The competent court is tasked to determine the respective rights of the complainant and other claimants, not only to place things in their proper place, to make the one who has no rights to said immovable respect and not disturb the other, but also for the benefit of both, so that he who has the right would see every cloud of doubt over the property dissipated, and he could afterwards without fear introduce the improvements he may desire, to use, and even to abuse the property as he deems best. But "for an action to quiet title to prosper, two indispensable requisites must concur, namely: (1) the plaintiff or complainant has a legal or an equitable title to or interest in the real property subject of the action; and (2) the deed, claim, encumbrance, or proceeding claimed to be casting cloud on his title must be shown to be in fact invalid or inoperative despite its prima facie appearance of validity or legal efficacy."

The issue relating to the grant of rights, title or award by the NHA determines whether the case for quieting of title may be maintained. If the petitioners are legitimate successors to or beneficiaries of Iluminardo upon his death – under the certificate of title, award, or grant, or under the special law or specific terms of the NHA program/project – then they possess the requisite interest to maintain suit; if not, then Civil Case No. 2741-MN must necessarily be dismissed.

Petitioners have failed to show their qualifications or right to succeed Iluminardo in his rights under the NHA program/project. They failed to present any title, award, grant, document or certification from the NHA or proper government agency which would show that Iluminardo and Prescilla have become the registered owners/beneficiaries/ awardees of Lots 18 and 19, or that petitioners are qualified successors or beneficiaries under the Dagat-Dagatan program/project, taking over Iluminardo’s rights after his death. They did not call to the witness stand competent witnesses from the NHA who can attest to their rights as successors to or beneficiaries of Lots 18 and 19. They failed to present proof, at the very least, of the specific law, provisions, or terms that govern the Tondo Dagat-Dagatan Foreshore Development Project which would indicate a modicum of interest on their part. For this reason, their rights or interest in the property could not be established.


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