Robles vs.

CA
March 14, 2000
Topic: Property; Quieting of title
Facts
Leon Robles primitively owned a land in Morong Rizal. When Leon died, his son Silvino Robles inherited the land. Both of them
declared the property under their name for taxation purposes. Upon the death of Silvino, his widow Maria dela Cruz and his children
inherited the property. They took adverse possession of it and paid the taxes thereon. The task of cultivating the land was assigned to one
of Silvinos son, Lucio Roles while the payment of the taxes was entrusted to their half brother, Hilario Robles.
In 1962, for unknown reasons, the tax declaration of the parcel of land in the name of Silvino Robles was canceled and transferred to one
ExequielBallena, father of Andrea Robles who is the wife of defendant Hilario Robles. Thereafter, ExequielBallena secured a loan from
the Antipolo Rural Bank, using the tax declaration as security. Somehow, the tax declaration was transferred to the name of Antipolo
Rural Bank and later on, was transferred to the name of defendant Hilario Robles and his wife. In 1996, Andrea Robles secured a loan
from the Cadona Rural Bank, Inc., using the tax declaration as security. For failure to pay the mortgage debt, foreclosure proceedings
were had and defendant Rural Bank emerged as the highest bidder during the auction sale in October 1968.
The spouses Hilario Robles failed to redeem the property and so the tax declaration was transferred in the name of defendant Rural
Bank. On September 25, 1987, defendant Rural Bank sold the same to the Spouses Vergel Santos and Ruth Santos who took possession
of the property and was able to secure Free Patent No. IV-1-010021 in their names.
Issue:
Whether or not the petitioners have the appropriate title that is essential for them to avail themselves of the remedy of quieting of title.
Held:
Yes. The land had previously been occupied by Leon and later by Silvino Robles, petitioners predecessor-in-interest, as evidenced by
the different tax declarations issued in their names. Also, the petitioners continued occupying and possessing the land from the death of
Silvino in 1942 until they were allegedly ousted therefrom in 1988.
The title of the petitioners over the land in dispute is superior to the title of the registered owner which is a total nullity. The long and
continued possession of petitioners under a valid claim of title cannot be defeated by the claim of a registered owner whose title is
defective from the beginning since Hilario mortgaged the disputed property to the Rural Bank of Cardona in his capacity as a mere co-
owner thereof. Clearly, the said transaction did not divest them of title to the property at the time of the institution of the Complaint for
quieting of title.
OBLEA V. CA|ESTEBAN, 244 SCRA 101
FACTS:
The lot in issue was originally registered in the names of Manuel Melencio, PuraMelencio, WilfredoWico and
MariabelleWico. But was subsequently re-registered in the name of Ramon Melencio (son of deceased Manuel Melencio),
PuraMelencio and the Wicos via a deed of sale.

On 6 June 1958 subject lot was bought by private respondent Juan S. Esteban from Mauricio Ramos who claimed to have
acquired the property from Ursula Melencio, the alleged administratrix of the estate of Manuel and PuraMelencio.

Meanwhile, petitioner Romeo V. Oblea leased a building located on the subject lot from a certain Marius Esteban, an
alleged son of private respondent Juan S. Esteban. Oblea eventually bought from Marius the lot on which the building
stood. As a consequence, on 4 July 1991 Juan Esteban filed an ejectment suit against petitioner Oblea.

MTC decided for Juan Esteban and ordered Oblea to vacate and pay arrears. On appeal, RTC affirmed MTC.

On 3 June 1993, the registered owners (Ramon Melencio, PuraMelencio and WilfredoWico and MariabelleWico) sold the
disputed lot to petitioner Oblea. Afterwards, Oblea together with the registered owners filed before the RTC an action for
quieting of title against Juan Esteban. They contended that the deeds of sale executed by Mauricio Ramos in favor of Juan
Esteban and by Ursula Melencio in favor of Mauricio Ramos were a nullity.

Meanwhile, the ejectment case was appealed thrice to the CA but all were denied.

In the appeal to the SC, Oblea asserts that the subsequent sale to him by the registered owners is a supervening event that
gave him a better right of possession and ownership. Hence the judgment of eviction can no longer be enforced.

ISSUE:
Whether or not a subsequent action to quiet title in the RTC divests the MTC of its jurisdiction over an ejectment case?

HELD:
No.The sole issue in an action for unlawful detainer is physical or material possession, i.e., possession de facto and not
possession de jure. The pendency of an action for quieting of title before the RTC does not divest the MTC of its jurisdiction
to proceed with the ejectment case over the same property. The subsequent acquisition of ownership by petitioners is not a
supervening event that will bar the execution of the judgment in said unlawful detainer case, the fact remaining that when
judgment was rendered by the MTC in the ejectment case, petitioner Oblea was a mere possessor of the subject lot.
Similarly, the fact that petitioners instituted a separate action for quieting of title is not a valid reason for defeating t he
execution of the summary remedy of ejectment. On the contrary., it bolsters the conclusion that the eviction case did not
deal with the issue of ownership which was precisely the subject matter of the action for quieting of title before the RTC.
With the finality of the decision in the ejectment case, execution in favor of the prevailing party has become a matter of right;
its implementation mandatory. It cannot be avoided.