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BENZON O. ALDEMITA v. HEIRS OF MELQUIADES SILVA

FACTS:

This case involves a petition for review on certiorari filed before the Supreme Court questioning the decision of the Court of Appeals (CA) affirming the decision of the Regional Trial Court (RTC). The case originated from a complaint for Quieting of Title filed by the Heirs of Melquiades Silva against the Heirs of Dionisia Vda. De Zabate. The respondents filed the complaint on November 25, 1998, and the petitioner filed a verified answer with special and affirmative defenses, counter-claim, and cross-claim on January 14, 1999. Subsequently, an Urgent Motion to Declare Defendants Roger Deiparine and Josephine Deiparine in Default and a Motion to Set Case for Pre-Trial were filed by the petitioner, which were granted by the court. On August 12, 1999, a pre-trial was conducted where the parties made stipulations of facts and/or admissions. The petitioner admitted that the disputed lot was registered in the name of Melquiades Silva and that the respondents have been in physical possession of the lot except for a portion claimed by the petitioner. The petitioner also admitted that a document denominated as "Kalig-onan sa Palit" was a forged document but argued that another document, "Kalig-onan sa Panagpalit nga Dayon," was executed by Melquiades Silva in favor of Dionisia Vda. De Zabate. The case underwent further proceedings, including the appointment of the PNP Regional Crime Laboratory Office VII as commissioner to determine the authenticity of signatures. A questioned document report was submitted to the court, and on September 15, 2000, the court considered the report's findings as established facts in the case. The parties subsequently agreed to submit the case for decision, and the petitioner filed a position paper. He later filed a motion to dismiss for lack of cause of action, which the RTC denied in its order dated April 20, 2001.

The petitioner filed a motion to dismiss, which was filed out of time, on April 6, 2001, despite being required to file an answer to the complaint. The motion to dismiss was not based on the exceptional grounds allowed under Rule 16 of the 1997 Rules on Civil Procedure. The court denied the motion to dismiss.

The petitioner filed a motion for reconsideration, but it was also denied by the court. The court emphasized that the heirs of the late Melquiades Silva, who were the registered owners of the disputed land, were the real parties in interest and could bring an action for quieting of title. The court further stated that there was already an ongoing special proceeding to determine the heirship of the plaintiffs, so it was unnecessary for the plaintiffs to be declared as heirs before they could be considered real parties in interest.

The trial court rendered its decision on August 20, 2001, declaring the respondents as the rightful owners of the disputed land. The court declared the documents purporting to transfer ownership of the land as null and void. The court also ordered the petitioner to respect the respondents' title and ownership and to vacate the premises. The petitioner appealed the decision to the Court of Appeals, questioning the court's rulings and orders.

The case involves a land dispute over the property covered by Original Certificate of Title (OCT) No. 1330 of Pcs-945. There were two respondents in the case: the Heirs of Quirino Mahusay and the Republic of the Philippines through the Solicitor General. The property in question was originally owned by the late Quirino Mahusay, who died without leaving a will and was survived by his children. OCT No. 1330 was subsequently issued in the name of Quirino Mahusay.

However, the Heirs of Quirino Mahusay claimed to have been in open, continuous, exclusive, and notorious possession of the disputed property even before the issuance of OCT No. 1330. They alleged that they have been using the land for agricultural purposes and that they have constructed improvements on it.

On the other hand, the Republic of the Philippines, through the Solicitor General, argued that the OCT No. 1330 was fraudulently obtained by Quirino Mahusay. They presented evidence showing that the land actually belonged to the public domain and was part of the Caraga Timber Reserve. They contended that Quirino Mahusay could not have legally acquired the property as it was beyond the coverage of the Public Land Act.

The Regional Trial Court (RTC) initially ruled in favor of the Heirs of Quirino Mahusay, but the decision was reversed on appeal by the Court of Appeals (CA). The CA held that the land involved in the case was public land and, therefore, not capable of private ownership by Quirino Mahusay. Hence, this appeal before the Supreme Court.

ISSUES:

  1. Whether or not the court a quo seriously erred and gravely abused its discretion when it declared the respondents as the rightful and absolute owners of the subject property despite their failure to present proof of appointment as administrator and a court order declaring them as legal heirs.

  2. Whether or not the court a quo seriously erred and gravely abused its discretion when it ruled that the questioned documents are null and void.

  3. Whether the Petition for Quieting of Title states a cause of action

  4. Whether the respondents should establish their status as legal heirs before prosecuting the case

  5. Whether the petitioner's motion to dismiss based on lack of cause of action should be granted

RULING:

  1. The petition must fail. The Court of Appeals (CA) affirmed the decision of the Regional Trial Court (RTC) in its entirety. The CA held that the question of whether the respondents are real parties-in-interest was raised for the first time on appeal and cannot be resolved without offending basic rules of fair play, justice, and due process. The CA also stated that the issues raised before the RTC were confined to the validity of the ancient documents and the various transactions. The CA further held that the RTC’s findings that the documents were forged are binding and conclusive on the parties as the petitioner failed to offer any evidence to prove their due execution and authenticity. Therefore, the CA affirmed the RTC's decision declaring the respondents as the rightful owners of the subject property and ordering the petitioner to respect and vacate the premises.

  2. The Petition for Quieting of Title sufficiently states a cause of action as it alleges the legal right of the respondents, the correlative obligation of the petitioner, and an act or omission of the petitioner that violates the respondents' right. The test is whether, assuming the truth of the facts alleged, the court can render a valid judgment in accordance with the prayer.

  3. The requirement for the respondents to establish their status as legal heirs before prosecuting the case is not necessary. The petitioner failed to raise this issue in his Answer or during the pre-trial. Moreover, the issue was raised belatedly after the case was already submitted for decision.

  4. The petitioner's motion to dismiss based on lack of cause of action should be denied as the Petition for Quieting of Title states a cause of action.

PRINCIPLES:

  • The failure to state a cause of action in a motion to dismiss should be filed within the time for but before filing the answer to the complaint or pleading asserting a claim.

  • Defenses and objections not pleaded in a motion to dismiss or answer are deemed waived, except for the failure to state a cause of action which may still be alleged in a later pleading or during trial.

  • Failure to state a cause of action is not an exception to the rule that defenses not raised in a motion to dismiss or answer are waived.

  • A cause of action requires the legal right of the plaintiff, the correlative obligation of the defendant, and an act or omission of the defendant that violates the right.

  • In determining whether an initiatory pleading states a cause of action, the test is whether, assuming the truth of the facts alleged, the court can render a valid judgment in accordance with the prayer.

  • Exceptions to the rule that allegations are hypothetically admitted as true and inquiry is confined to the face of the complaint include when the falsity of the allegations is subject to judicial notice or if the allegations are legally impossible.

  • The capacity of the parties to sue must be raised at the earliest possible time and failure to do so may result in the waiver of such defense.

  • The issue of whether the persons enumerated in the complaint are the actual heirs may be addressed in a separate proceeding for declaration of heirs and settlement of the estate.

  • An ancient document is one that is more than 30 years old, found in the proper custody, and unblemished by any alteration or circumstance of suspicion.

  • The due execution and authenticity of a document must be proven, even if it is considered an ancient document, to determine its legal effect and validity.

  • An agreement between the parties to submit a disputed document to a commissioner for determination of authenticity results in the commissioner's findings being considered as findings of fact in the case, and the parties are bound by these findings.