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GASPAR CALACALA v. REPUBLIC

FACTS:

The spouses Camilo Calacala and Conchita Calacala owned a parcel of land in Rosales, Pangasinan. In a criminal case, they used their land as a property bond to secure the provisional release of an accused. However, the accused failed to appear in court, resulting in the forfeiture of the bond in favor of the government. A writ of execution was issued, leading to the levy on the land and its subsequent sale in a public auction to the respondent Republic. The sale was registered on the land's certificate of title, allowing the Calacalas a chance to redeem it. However, they both passed away without redeeming the property. The heirs of the Calacalas filed a complaint seeking to cancel the entries on the land's certificate of title. The respondent Republic argued that the complaint failed to state a cause of action and that the right to redeem had already prescribed. The trial court agreed with the Republic and dismissed the case, prompting the petitioners to appeal.

ISSUES:

  1. Whether the complaint for Quieting of Title filed by petitioners sufficiently states a cause of action.

  2. Whether the case for Quieting of Title has prescribed.

  3. Whether respondent Republic of the Philippines has perfected its title to the land in question.

RULING:

  1. The Supreme Court ruled in favor of respondent Republic of the Philippines. The Court affirmed the trial court's dismissal of petitioners' complaint for Quieting of Title. The Court held that the action for quieting of title is essentially a common law remedy grounded on equity. In this case, the Court found that the complaint failed to establish any cloud or doubt on the title of the respondent. The Court also held that the one-year redemption period had expired and the respondent's rights and title to the property were perfected by the failure of petitioners to redeem the land within that period.

PRINCIPLES:

  • An action for quieting of title is a common law remedy for the removal of any cloud or doubt on the title to or any interest in immovable property.

  • The one-year redemption period provided by law is a period within which the mortgagor or his successors-in-interest may redeem the property sold at public auction. Failure to redeem within this period perfects the title of the purchaser at the foreclosure sale.