ANASTACIA VDA. DE AVILES v. CA

## FACTS:

The case involves a boundary dispute between the petitioners and the private respondent over a parcel of land in Pangasinan. The petitioners claim to be the actual possessors of the land, alleging it to be part of their father's share in the estate of their deceased parents. They assert peaceful possession of the land since 1957. In 1983, the private respondent constructed a bamboo fence on a portion of the land, which the petitioners claim encroached on their property and disturbed their peaceful possession. The petitioners filed a complaint for quieting of title to settle the dispute. The trial court dismissed the complaint, ordering the parties to employ the services of a land surveyor to determine the extent and boundary limit. The petitioners appealed to the Court of Appeals, which affirmed the dismissal, holding that an ejectment suit should have been filed instead. The petitioners raised the issues of whether quieting of title is the proper remedy and whether the court should have determined the respective rights of the parties. The petitioners argued that the private respondent's claim of ownership is without basis, given the length of time it took for him to assert ownership and his inaction during previous events involving the land. The private respondent, however, disputed the petitioners' claim of encroachment, stating that he was merely repairing an old bamboo fence that had been there since 1957.

ISSUES

a. Whether or not the action for quieting of title is the proper remedy for resolving a boundary dispute.

b. Whether or not the courts are required to declare the respective rights of the parties concerning the land in question.

RULING

a. The Supreme Court agreed with the respondent Court that quieting of title is not the appropriate remedy for settling a boundary dispute. The Court clarified that an action to quiet title applies only to remove any doubts, uncertainty, or cloud upon real property titles caused by documents that are apparently valid but are, in fact, invalid, ineffective, voidable, or unenforceable. A boundary dispute does not involve such documents, hence quieting of title cannot be applied.

b. Concerning the declaration of the parties' respective rights, the Supreme Court noted that actions for declaratory relief are specific and can only be brought under certain conditions as provided by Rule 64 of the Rules of Court. Since the matter in question pertains to a boundary dispute and not a controversy arising from interpretation or validity of a document, deed, will, contract, statute, or ordinance, a declaratory relief does not apply. Furthermore, in an action for quieting of title, the court cannot adjudicate rights beyond determining whether there is a cloud on the title, such as determining the boundaries of property, which belongs to a separate and actual adversarial proceeding.

PRINCIPLES

  1. Quieting of Title: It is a remedy used to remove any cloud, doubt, or uncertainty affecting a title to real property. Applicable only if there’s an instrument or claim casting such doubts.

  2. Boundary Dispute: Not applicable for quieting of title as it does not involve any invalid or uncertain documents affecting property ownership but relates to the physical location and limits of the property.

  3. Declaratory Relief: Only applicable to issues concerning the construction or validity of documents (deeds, wills, contracts) or statutes, and not to physical boundary disputes.

  4. Action Proper for Boundary Disputes: Issues regarding boundaries should be resolved through specific adversarial proceedings where possession and ownership are considered, such as actions for recovery of possession or forcible entry.