FACTS:
The case involves a 338 square meter parcel of land located in the Poblacion of Maasin, Southern Leyte. The petitioners, who are heirs of the former owners of the land, filed a Complaint for Recovery of Property and Declaration of Nullity of Deed of Sale, Certificate of Title, and Damages against the respondents. The petitioners claimed that they inherited the land from their late parents and that the respondents falsely claimed ownership by alleging that they bought the land from a previous owner. The petitioners sought the nullification of the deeds of sale and the transfer certificate of title in the name of the respondents. They also asked for damages and attorney's fees.
The respondents filed a Motion to Dismiss the Complaint, arguing that the court lacked jurisdiction over the case, that the petitioners' cause of action was barred by prescription, laches, and indefeasibility of title, and that the complaint did not state sufficient cause of action against them as buyers in good faith. The trial court denied the motion, and the respondents filed a motion for reconsideration, which was also denied.
Unsatisfied, the respondents filed a special civil action for certiorari with the Court of Appeals (CA) to question the trial court's denial of their motion to dismiss. The CA denied the action and dismissed the respondents' petition. The respondents filed a motion for reconsideration, but it was also denied.
Meanwhile, the petitioners filed an Amended Complaint to include the assessed value of the land. The respondents filed a Motion to Dismiss the Amended Complaint on the same grounds as before. The trial court denied the motion, and the respondents filed a motion for reconsideration, which was again denied.
The respondents then filed another special civil action for certiorari with the CA, seeking to set aside the trial court's orders and to have the complaint dismissed. The CA granted the petition and ordered the trial court to dismiss the case, citing indefeasibility of title, prescription, and the presumption that the respondents were buyers in good faith.
The petitioners filed a motion for reconsideration, but it was denied by the CA. Hence, they filed a petition for review on certiorari with the Supreme Court. The issues raised in the petition include procedural matters regarding the timeliness of the respondents' motion to dismiss and substantive matters regarding the grounds for dismissal raised by the respondents.
The Supreme Court held that the petitioners' arguments lacked merit. It ruled that the timeliness of the respondents' motion to dismiss was not raised in the lower courts and was, therefore, barred by estoppel. It also found that the grounds for dismissal raised by the respondents, including indefeasibility of title, were valid.
ISSUES:
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Procedurally, whether or not the Court of Appeals erred in giving due course to respondents' second motion to dismiss filed on November 21, 2003 on the amended complaint filed on August 16, 2000.
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Substantively, whether or not the Court of Appeals erred in ordering the Regional Trial Court to dismiss the case and enjoining it from proceeding with the case on the ground of indefeasibility of title, prescription, and/or laches.
RULING:
- The Court dismissed the petition for lack of merit.
PRINCIPLES:
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Issues not raised before the lower court are barred by estoppel.
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A title becomes indefeasible and incontrovertible after the lapse of time.
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Owners of a registered title are presumed to be purchasers in good faith and for value.