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NEMESIO GOCO v. CA

FACTS:

Lot No. 2042 in Calapan, Oriental Mindoro was originally owned by Feliciano Alveyra. In 1952, the Municipality of Calapan acquired a one-half interest in Lot No. 2042 as satisfaction for a judgment award against Alveyra. However, during registration, the entire lot was included in Transfer Certificate of Title (TCT) No. 21306, cancelling Original Certificate of Title (OCT) No. 529.

To settle the conflicting rights over Lot No. 2042, an action to quiet title was filed and eventually reached the Court of Appeals (CA). The CA decided to subdivide Lot No. 2042 into two lots: Lot No. 2042-A, declared as the property of the heirs of Alveyra, and Lot No. 2042-B, declared owned by the Municipality of Calapan.

While the litigation between the heirs of Alveyra and the Municipality of Calapan was ongoing, the heirs sold their one-half interest in Lot No. 2042-A to the respondent spouses Hicoblino and Lourdes Catly (respondent Catlys). The Catlys then petitioned for the judicial approval of the subdivision plan of Lot No. 2042-A, which was granted by the trial court.

In 1999, the respondent Catlys alleged that a portion of Lot No. 2042-A was being occupied by the petitioners and sought to recover possession of the lot. In response, the petitioners filed a complaint to declare the nullity of the four certificates of title issued in the Catlys' names. They claimed to be lawful occupants of Lot No. 2042 since 1946 as lessees of the Municipality of Calapan. The petitioners argued that the titles issued to the Catlys included portions that were part of Lot No. 2042-B, which belonged to the Municipality of Calapan. The trial court dismissed the complaint, and the Court of Appeals affirmed this decision. Now, the petitioners seek the reversal of the CA's rulings.

ISSUES:

  1. Whether the petitioners have a cause of action to challenge the titles issued in respondent Catlys' names.

  2. Whether the petitioners are the real parties in interest in assailing and seeking the annulment of the respondents' titles.

RULING:

  1. No, the petitioners do not have a cause of action to challenge the titles issued in respondent Catlys' names. The titles obtained by the respondents are separate and distinct from the land occupied by the petitioners. Even if a portion of respondent Catlys' lot includes the land owned by the Municipality of Calapan, the petitioners, as mere lessees, do not have sufficient interest to assail the titles.

  2. No, the petitioners are not the real parties in interest in assailing and seeking the annulment of the respondents' titles. The petitioners' lease contract only covers the land owned by the Municipality of Calapan, not the land owned by the respondents. Thus, their claimed vested rights in the land owned by the Municipality of Calapan are not impaired by the respondents' titles.

PRINCIPLES:

  • A cause of action is the act or omission by which a party violates the right of another, and the existence of a cause of action is determined by the allegations in the complaint.

  • Only real parties in interest have the standing to challenge the validity of a title. A real party in interest is the party who stands to be benefited or injured by the judgment in the suit or the party entitled to the avails of the suit.