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SPS. MARIO ONG v. SPS. ERGELIA OLASIMAN

FACTS:

On June 1, 1992, Paula Verzano sold an unregistered parcel of land to her niece Bernandita Verzano-Matugas. The land was described in the deed of sale and was divided into two lots, Lot 4080 and Lot 4091, which were covered by separate tax declarations. Bernandita attempted to register the land but did not complete the process.

Paula Verzano died on November 26, 1992, and was survived by her siblings and the children of her deceased brother. On November 22, 1995, Demetrio Verzano executed an extrajudicial settlement and sold Lot 4080 to Carmelita Ong. Carmelita then cancelled the tax declaration for Lot 4080 and obtained a new one in her name.

On February 5, 1996, Bernandita sold Lot 4080 to the respondents, Ergelia and Leonardo Olasiman. In 1997, the Olasimans filed a complaint against the petitioners, seeking the annulment of the extrajudicial settlement and claiming damages. The Olasimans alleged that they had been in possession of the land since time immemorial and were disturbed by the petitioners' actions.

The petitioners argued that the Olasimans were not the real parties in interest and that the court did not have jurisdiction over the case. The trial court applied Article 1544 of the Civil Code and dismissed the Olasimans' complaint, ruling that the petitioners were buyers in good faith and were the first to possess the land.

ISSUES:

  1. Whether or not the Regional Trial Court (RTC) has jurisdiction over the case filed by respondents.

  2. Whether or not petitioners spouses Ong are buyers in good faith and the first to possess the questioned lot.

RULING:

  1. The RTC has jurisdiction over the case. The jurisdiction of the RTC is determined by the allegations in the complaint and the character of the relief sought. In this case, respondents filed a complaint for annulment of the "Extrajudicial Settlement by Sole Heir and Sale," quieting of title, and damages. The complaint involves a dispute over ownership and possession of property, which falls within the jurisdiction of the RTC.

  2. Petitioners spouses Ong are considered buyers in good faith and the first to possess the questioned lot. Article 1544 of the Civil Code provides that if the same immovable property is sold to different vendees, ownership shall belong to the person acquiring it who in good faith first recorded it in the Registry of Property. In this case, petitioners spouses Ong were able to establish their relationship with the registered owner, secured clearances from various offices, and caused the cancellation of the tax declaration in the name of Paula Verzano. They are also the first to possess the property. Therefore, they are considered buyers in good faith and are entitled to ownership of the land.

PRINCIPLES:

  • The jurisdiction of the court is determined by the allegations in the complaint and the character of the relief sought.

  • In cases where the same immovable property is sold to different vendees, ownership shall belong to the person acquiring it who in good faith first recorded it in the Registry of Property.