FACTS:

The case involves a dispute over the ownership and possession of a parcel of agricultural land in Sorsogon, Philippines. Jose Extremadura filed a case against his brother, Manuel Extremadura, and his nephew, Marlon Extremadura, claiming that he purchased the land from his aunt through a Deed of Absolute Sale. Jose placed the land in Manuel's care in exchange for the latter's delivery of the land's produce. However, Manuel and Marlon refused to deliver the produce or vacate the land despite Jose's demands.

In their defense, Manuel and Marlon argued that they have been in possession of the land for almost 50 years and that Jose's action is barred by prescription or laches.

The Regional Trial Court ruled in favor of Jose, declaring him as the owner of the land. However, the Court of Appeals reversed the decision, holding that Jose failed to establish legal and equitable title over the land.

The heirs of Jose filed a petition for review on certiorari before the Supreme Court.

ISSUES:

1. Whether the plaintiff has legal or equitable title to, or interest in, the subject property.

2. Whether the claim of the respondents, alleging ownership of the subject property, is valid or inoperative.

3. Whether Jose Extremadura was able to prove his title over the subject land.

4. Whether Manuel Extremadura was able to establish his ownership of the land.

5. Whether the action for quieting of title in Civil Case No. 2005-7552 should prosper.

RULING:

1. The plaintiff has satisfied the requirement of having legal or equitable title over the subject property. The plaintiff's equitable title was established through a contract of sale, evidenced by a notarized Deed of Absolute Sale. The previous owner, Corazon, had the right to transfer the land as the owner. It was also established that the plaintiff paid the required taxes on the property.

2. The claim of the respondents, alleging ownership of the subject property, is invalid. The execution of a public instrument, such as a notarized Deed of Absolute Sale, constitutes constructive delivery and transfers ownership of the property to the buyer, unless it is clearly inferred otherwise. The respondents failed to provide evidence that the subject land was not placed under the plaintiff's control and possession. The prima facie presumption of constructive delivery was not negated.

3. The Court held that Jose Extremadura was able to prove his title over the subject land. The Court considered Jose's execution of the Deed of Absolute Sale in his favor, as well as his exercise of rights and obligations as owner, such as receiving the fruits of the land and paying taxes on it. On the other hand, Manuel Extremadura failed to establish his ownership of the land, relying only on the fact that he was born and lived on the property. The Court further ruled that the action for quieting of title in Civil Case No. 2005-7552 should prosper in favor of Jose's heirs.

PRINCIPLES:

• An action for quieting of title requires the plaintiff to have legal or equitable title to, or interest in, the subject property.

• Equitable title is derived through a valid contract or relation, and is based on recognized equitable principles.

• The execution of a public instrument, like a notarized Deed of Absolute Sale, constitutes constructive delivery and transfers ownership of the property, unless it is clearly inferred otherwise.

• Possession is acquired through material occupation or the exercise of a right, or by the fact that the property is subject to the action of one's will or the legal formalities for acquiring such right.

• Possession may be exercised in one's own name or in that of another.

• Tax declarations or realty tax payments are good indicia of possession in the concept of ownership.

• Payment of taxes on a property manifests the intention to acquire title and strengthens one's bona fide claim of ownership.

• Merely being born and living on a property does not automatically confer ownership.