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SPS. ROBERTO ABOITIZ v. SPS. PETER L. PO

FACTS:

This case involves two consolidated Petitions for Review on Certiorari filed by the Spouses Roberto Aboitiz and Maria Cristina Cabarrus (Spouses Aboitiz) and the Spouses Peter Po and Victoria Po (Spouses Po) challenging the Court of Appeals' decision, which affirmed the Regional Trial Court's (RTC) decision that the Spouses Po are the rightful owners of a parcel of land located in Cabancalan, Mandaue City, registered initially as Original Certificate of Title No. 0-887 and titled under the name of Roberto Aboitiz. The land, referred to as Lot No. 2835, originally belonged to the late Mariano Seno, who sold it to his son Ciriaco Seno in 1973. Ciriaco, in turn, sold the land to Victoria Po in 1978. In 1990, Peter Po discovered that Ciriaco executed a quitclaim on Lot No. 2807 favoring Roberto Aboitiz, which included a declaration of ownership over Lot No. 2835. Consequently, Ciriaco and the Spouses Po executed a Memorandum of Agreement to address the quitclaim. However, also in 1990, the Mariano Heirs, including Ciriaco, executed separate deeds of absolute sale for Lot No. 2835 in favor of Roberto Aboitiz, who subsequently subdivided and sold portions of the lot to respondents Ernesto and Jose Aboitiz. The Spouses Po declared Lot No. 2835 for taxation purposes in 1991, while Roberto did so in 1992, which highlighted a notation suggesting duplicate ownership. In 1993, Roberto successfully applied for original registration of Lot No. 2835, leading to the issuance of Original Certificate of Title No. 0-887 in his name. Subsequently, the Spouses Po filed a complaint in 1996 to recover the land and nullify the title, which the RTC granted in 2009. The Court of Appeals partially affirmed the RTC decision, recognizing the Spouses Po as the rightful owners but upholding the validity of the titles issued to respondents Ernesto, Jose, and Isabel Aboitiz, considering them as innocent buyers in good faith.

ISSUES:

1. Whether the Regional Trial Court has jurisdiction over the complaint filed by the Spouses Po.

2. Whether the action for reconveyance and annulment of title filed by the Spouses Po is barred by prescription.

3. Whether the doctrines of estoppel and laches apply to bar the Spouses Po's action.

4. Whether the land registration court's finding that Ciriaco Seno only held the property in trust for the Mariano Heirs is binding as res judicata in this case.

5. Whether the Deed of Absolute Sale between Ciriaco Seno and the Spouses Po should be considered as evidence of their entitlement to the property.

6. Whether the Mariano Heirs are indispensable parties in the action for reconveyance.

7. Whether respondents Jose Maria Moraza, Ernesto Aboitiz, and Isabel Aboitiz are innocent purchasers for value and in good faith.

RULING:

1. Yes, the Regional Trial Court has jurisdiction over the action for reconveyance, cancellation of title, and damages filed by the Spouses Po as it falls under actions involving title to or possession of real property.

2. No, the action for reconveyance filed by the Spouses Po is not barred by prescription. An action for reconveyance based on implied or constructive trust prescribes in 10 years from the issuance of the title. The action was filed within the 10-year prescriptive period.

3. No, the doctrines of estoppel and laches do not bar the action of the Spouses Po. There was no undue delay in asserting their rights over the property, and they actively protected their interests upon discovering the adverse claims.

4. No, the land registration court's finding that Ciriaco merely held the property in trust for the Mariano Heirs is not binding as res judicata in the reconveyance action. The Spouses Po were not parties to the land registration case and were unaware of it.

5. Yes, the Deed of Absolute Sale between Ciriaco Seno and the Spouses Po should be considered as evidence of their entitlement to the property. The deed was duly notarized and thus presumed regular and authentic.

6. No, the Mariano Heirs are not indispensable parties in the action for reconveyance. They had already sold all their interests in the property, thus, they would not be directly affected by the ruling.

7. Yes, respondents Jose Maria Moraza, Ernesto Aboitiz, and Isabel Aboitiz are considered innocent purchasers for value and good faith as there was no showing that they had prior knowledge of the defect in the title.

PRINCIPLES:

  1. Jurisdiction Actions involving title to or possession of real property fall under the exclusive original jurisdiction of the Regional Trial Courts.

  2. Prescription An action for reconveyance based on implied or constructive trust prescribes in 10 years from the issuance of the title.

  3. Laches There is laches when a party fails to assert a right within a reasonable time, causing prejudice to the adverse party due to the delay. However, laches require substantive proof of abandonment of the claim.

  4. Res Judicata The principle does not apply if the party claiming ownership had no opportunity to present their claim in the original case, especially in actions for reconveyance.

  5. Validity of Notarized Documents Notarized documents are presumed regular and authentic unless overturned by clear and convincing evidence.

  6. Indispensable Parties Only those with a direct interest affected by the court's decision are indispensable parties. Sellers of already transferred interests are not indispensable parties.

  7. Innocent Purchasers for Value Purchasers relying on the face of a Torrens title are not obliged to inquire further unless there is actual knowledge or circumstances arousing suspicion about the title’s validity.