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VILMA QUINTOS v. PELAGIA I. NICOLAS

FACTS:

The case involves a dispute over a 281 sqm. parcel of land in Camiling, Tarlac. The property was owned by the late Bienvenido and Escolastica Ibarra, who had ten children, including the petitioners and respondents in this case. In 1999, both parents passed away, leaving the siblings as co-owners of the property. In 2002, the respondent siblings filed a partition case against the petitioners, but it was dismissed by the trial court in 2004 due to the failure of parties to appear. The dismissal became final and a certificate of finality was issued in 2008. Respondent siblings then executed a Deed of Adjudication in 2004, transferring the property to all ten siblings. A new transfer certificate of title (TCT) was issued in their names. Subsequently, the respondent siblings sold their 7/10 undivided share of the property to the spouses Recto and Rosemarie Candelario. A new TCT was issued in favor of the Candelarios. In 2009, the petitioners filed a complaint for Quieting of Title and Damages, claiming that they have acquired ownership over the property through acquisitive prescription and that they have been in adverse possession of the property. The trial court dismissed the complaint, ruling that there was no evidence that the property was bequeathed to the petitioners and that the respondent siblings were entitled to their shares. The CA affirmed the decision, stating that the partition of the property was in order. The petitioners raised several issues before the Supreme Court, including their claim of equitable title, the bar of laches or res judicata on the counterclaim for partition, and the correctness of the subdivision agreement as basis for partition.

ISSUES:

  1. Whether or not the petitioners were able to prove ownership over the property.

  2. Whether or not the respondents' counterclaim for partition is already barred by laches or res judicata.

  3. Whether or not the CA was correct in approving the subdivision agreement as basis for the partition of the property.

RULING:

  1. Petitioners were not able to prove equitable ownership over the property. The Court found that the petitioners failed to prove the two requisites for quieting of title: (a) legal or equitable title to the real property, and (b) invalidity of the deed or claim casting a cloud on the title. Consequently, the Court upheld the findings of the RTC and the CA as to the co-ownership of the property between petitioners and respondent spouses.

  2. The counterclaim for partition is not barred by prior judgment (res judicata). The previous dismissal of the action for partition (Civil Case No. 02-52) for failure to prosecute did not operate as a dismissal on the merits that would bar a subsequent action for partition, as per Art. 494 of the Civil Code, which allows a co-owner to demand partition at any time.

  3. The counterclaim for partition is not barred by laches. The Court found that the respondents did not neglect to assert their right over the property. They had filed an earlier action for partition, and entered into lease agreements evidencing their exercise of ownership rights.

  4. The CA erred in approving the Agreement for Subdivision. The Agreement of Subdivision, executed without the consent or consultation of petitioners, was invalid. The case was remanded to the RTC for partition in accordance with Rule 69 of the Rules of Court.

PRINCIPLES:

  1. Quieting of Title: For an action to quiet title to prosper, two requisites must concur: (1) the plaintiff has a legal or equitable title to the property; and (2) the deed or claim casting a cloud on the title must be invalid.

  2. Res Judicata: There is res judicata when a final judgment on the merits, rendered by a court having jurisdiction, precludes the parties from relitigating the same issues.

  3. Laches: Laches is the failure to assert a right for an unreasonable period, warranting a presumption that the party has abandoned the right.

  4. Co-ownership and Partition: Under Article 494 of the Civil Code, a co-owner may demand partition at any time. Partitions are governed by agreements between the parties or in accordance with the Rules of Court.

  5. Procedural and Substantive Law: Substantive rights provided by the Civil Code cannot be amended by procedural rules. The Rules of Court must be consistent with statutory provisions.

  6. Invalid Agreements: Agreements executed without the essential requisite of consent are invalid and cannot serve as the basis for legal actions such as partition.