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PHIL-VILLE DEVELOPMENT v. MAXIMO BONIFACIO

FACTS:

Phil-Ville Development and Housing Corporation (Phil-Ville) is the registered owner of three parcels of land in Caloocan City, acquired in 1984. The Maysilo Estate, which included the said lots, was subject to a petition for substitution of names on the title in 1961, resulting in subsequent proceedings for the estate's partition. Eleuteria Rivera filed a motion for partition and segregation of portions of the Maysilo Estate, which was initially granted by the Regional Trial Court (RTC). However, a petition for certiorari was filed contesting the partition, leading to the Court of Appeals setting it aside. Phil-Ville, despite the Court of Appeals' decision, filed a complaint for quieting of title and damages against the surviving heirs of Eleuteria Rivera Vda. de Bonifacio and the Register of Deeds of Caloocan City.

Senator Marcelo B. Fernan filed a resolution for Senate Committees to investigate the irregularities surrounding the titling of properties in the Maysilo Estate. The Caloocan RTC eventually ordered the quieting of Phil-Ville's titles and declared the titles in their name as valid, while nullifying Eleuteria Rivera's title. Respondents filed a Notice of Appeal but withdrew and filed a Petition for Review on Certiorari with the Supreme Court. The Supreme Court referred the petition to the Court of Appeals, which dismissed the appeal as regards certain parties. Phil-Ville sought reconsideration, but the Court of Appeals denied the motion. Hence, Phil-Ville filed this petition before the Supreme Court.

ISSUES:

  1. Whether the Court of Appeals had the jurisdiction to resolve the ownership of the lots in question.

  2. Whether the dismissal of the appeal in CA-G.R. CV No. 66547 is binding on the respondents.

  3. Whether the trial court erred in taking cognizance of petitioner's action for quieting of title.

  4. Whether the petitioner has presented sufficient evidence to establish its claim over the contested property.

  5. Whether the respondents have presented competent evidence to dispute petitioner's claim.

  6. Whether Eleuteria Rivera is a legitimate heir of Maria de la Concepcion Vidal

  7. Whether the deed claimed to be casting cloud on petitioner's title is in fact invalid or inoperative

  8. Whether an action to quiet title can be considered as a proceeding quasi in rem.

  9. Whether the action for quieting of title filed by the petitioner falls within the purview of Rule 63 of the Rules of Court on Declaratory Relief.

RULING:

  1. The issue raised by the respondents, regarding the ownership of the lots, was a question of fact that is beyond the power of the Supreme Court to resolve. The Court of Appeals properly assumed jurisdiction over respondents' case after it was referred to by the Supreme Court.

  2. The dismissal of the appeal in CA-G.R. CV No. 66547 is not binding on the respondents. The appellate court recognized the withdrawal of the appeal filed by respondents.

  3. The trial court did not err in taking cognizance of petitioner's action for quieting of title. The nature of an action is determined by the material allegations of the complaint and the character of the relief sought by the plaintiff.

  4. The Supreme Court found that the petitioner has presented competent evidence to establish its claim over the contested property, including the Proyecto de particion de la Hacienda de Maysilo, tax receipts, and a Plan showing the location of the property.

  5. The respondents have failed to present competent evidence to dispute petitioner's claim. Their claim based on TCT No. C-314537 was already set aside by the Court of Appeals, and it lacks legal basis.

  6. Eleuteria Rivera is not a legitimate heir of Maria de la Concepcion Vidal as she was born two years before Vidal, making it physically impossible for her to be an heir.

  7. The deed claimed to be casting cloud on petitioner's title, TCT No. C-314537 in the name of Eleuteria Rivera, is invalid. However, it does not cover the same parcels of land as petitioner's titles and there is no overlapping of their boundaries.

  8. Yes, an action to quiet title can be considered as a proceeding quasi in rem. In an action quasi in rem, the purpose of the proceeding is to subject the interests of the named defendant to the obligation or loan burdening the property. The judgment in this type of action is binding only upon the parties who joined in the action and does not affect the rights or interests of all possible claimants.

  9. Yes, the action for quieting of title filed by the petitioner falls within the purview of Rule 63 of the Rules of Court on Declaratory Relief. An action for declaratory relief is appropriate when there has been no actual breach of the instruments involved or of the rights arising thereunder. Its purpose is to secure an authoritative statement of the rights and obligations of the parties under a statute, deed, or contract for their guidance in the enforcement thereof or compliance therewith. In this case, the petitioner filed its complaint for quieting of title before it could be dispossessed of the subject properties, and it sought a declaration of its rights and the validity of its titles against the respondents'.

PRINCIPLES:

  • Quieting of title is a common law remedy for the removal of any cloud upon, doubt, or uncertainty affecting title to real property.

  • An action for quieting of title requires two requisites to concur: (1) the plaintiff has a legal or equitable title or interest in the real property subject of the action, and (2) the deed, claim, encumbrance, or proceeding casting cloud on his title must be shown to be invalid or inoperative despite its prima facie appearance of validity or legal efficacy.

  • Documentary evidence, such as tax receipts and plans, may be used to establish ownership of property.

  • The burden of proof is on the party asserting a claim over disputed property.

  • In an action for quieting of title, the instrument, claim, encumbrance, or proceeding claimed to be casting cloud on the title must be shown to be in fact invalid or inoperative, despite its prima facie appearance of validity or legal efficacy.

  • A cloud on title consists of an apparently valid or effective instrument, record, claim, encumbrance, or proceeding that is in truth and in fact invalid, ineffective, voidable, or unenforceable, and may be prejudicial to the title sought to be quieted.

  • An action quasi in rem subjects the interests of the named defendant to the obligation or loan burdening the property and the judgment in such action is binding only upon the parties who joined in the action.

  • An action for declaratory relief seeks an authoritative statement of the rights and obligations of the parties under a statute, deed, or contract for their guidance in the enforcement or compliance therewith, and it may be entertained before any breach or violation of the instrument involved.