Clado-Reyes v.

Spouses Limpe
GR No. 163876 || July 9, 2008
QUISIMBING, J.

CASE DOCTRINE (with reference to the topic in the syllabus)

An action for quieting of title originated in equity jurisprudence to secure an adjudication that a claim of title to or an
interest in property, adverse to that of the complainant, is invalid, so that the complainant and those claiming under him
may be forever free from any danger of hostile claim.

SUMMARY:
Herein petitioners claim ownership over a portion of land because they believe that they acquired such land through their
predecessor-in-interest because the former owner of said land verbally promised to give it to Marmeto in exchange of his
tenancy rights as a tiller thereof. They have been in continued possession of the land until they received a letter from the
respondents asserting ownership over the disputed lot. The RTC ruled in favor of the respondents because of the
documentary evidence that the latter has presented and such was affirmed by the Court of Appeals. When they brought
the issue to the Supreme Court, it still ruled in favor of the petitioners.

FACTS:
● The petitioners filed an action to quiet title, reconveyance, and damages against petitioners and alleged that they
have been occupying the portion (2,445sqm.) of the disputed lot (in Guiguinto, Bulacan) since 1945 through their
predecessor-in-interest, Marmeto B. Reyes.
○ They claimed that they have been occupying the disputed lot since 1945 through their predecessor-in-
interest, Mamerto B. Reyes; that during his lifetime, Marmeto had accepted a verbal promise of the former
lot owner, Felipe Garcia, to give the disputed lot to him in exchange of his tenancy rights as a tiller
thereof. They presented two documents: (1) Certification and (2) “Pagpapatunay”, allegedly executed by
Simeon I. Garcia, Felipe’s eldest son.
○ They also alleged that whenever the respondents visited the lot, Julius Limpe would promise to deliver the
certificate of title to them until October 1944 when the petitioners received a letter from respondents
asserting ownership over the disputed lot.
● In their Answer, the respondents contended that they are the legal owners of the lot by virtue of a Deed of
Exchange of Real Estate and Deed of Absolute Sale between them and Farm-Tech Industries, Incorporated.
○ They also presented Transfer Certificate of Title, Tax Declarations, and realty tax receipts all registered
and declared under their name.
● RTC ruled in favor of respondents and held that the certificate of title, tax declarations and realty tax receipts
indisputably established respondents’ ownership over the lot.
○ These pieces of evidence, said the trial court, prevail over petitioners’ allegation of an “undocumented
promise” by the former lot owner which is ineffective or unenforceable under the law.
● The Court of Appeals affirmed the trial court’s ruling and held that petitioners have no title whatsoever upon
which respondents’ title could cast a cloud, as they were the ones casting doubt on respondents’ title.
○ It further held that Simeon I. Garcia was not the real owner of the lot; thus, he could not make an effective
conveyance thereof.

PARTIES’ ARGUMENTS (if applicable):

PETITIONER/PLAINTIFF RESPONDENT/DEFENDANT

● In their petition to the SC, they cited Sec. 4, Art. ● With regard to the petitioners’ appeal, they
XIII of the 1987 Constitution and Sec. 2 of the assert that they are buyers in good faith when they
CAR Law, stating that their title was founded upon purchased the lot free from all liens and
those provisions, which were enacted for the encumbrances. They further averred that they are

B2023(CARINO) - LAW 102, PROF. MIA GENTUGAYA

 benefit of farmers.
● They further contended that the respondents are
not purchasers in good faith because they were
fully aware of petitioners’ actual possession of the
lot when they purchased the same.
ISSUE(S), HOLDING, AND RATIO:
RULING
WON the petitioners have a cause of action to
quiet title, reconveyance, and damages
against respondents? -- NO
DISPOSITIVE:
WHEREFORE, the instant petition is DENIED for utter lack of merit. The Decision dated February 20, 2004 and the
Resolution dated June 9, 2004, of the Court of Appeals in CA-G.R. No. 70170 are AFFIRMED. Costs against petitioners.
not obliged to go beyond the face of a TCT in the
absence of any cloud therein.
● They argue that the former’s action must fail
because they failed to prove (1) that their
predecessor-in-interest, Marmeto, was a farmer;
(2) that the lot was agricultural and not a
commercial lot; and (3) that they are qualified
beneficiaries under the agrarian reform law.
● They also point out that the Certification and
“Pagpapatunay” are hearsay since Simeon was
not presented to the court and since the property
mentioned in the document was not specifically
described as the property litigated herein.
RATIO
● Arts. 476 and 477 of the New Civil Code provides two
indispensable requisites for an action to quiet title could
prosper:
○ That the plaintiff or complainant has a legal or an
equitabl etitle to or interest in the real property subject
of the action; and
○ That the deed, claim, encumberance or proceeding
claimed to be casting cloud on his title must be shown
to be in fact invalid or inoperative despite its prima
facie appearance of validity or legal efficacy.
● The laws relied on by the petitioners and the pieces of
evidence presented by both parties is clearly insufficient to
prove that the petitioners have any legal or equitable title over
the disputed lot.
○ They merely cited Sec. 4, Art. XIII of the Constitution
and Sec. 2 of the CAR Law without arguing on the
matter. There was no positive evidence to prove that
their predecessor had legal title, that the lot was an
agricultural lot, and that they are qualified beneficiaries
under CAR Law.
○ The Certification and “Pagpapatunay” that were
presented are not original copies and Simeon I. Garcia
was not presented in court to prove the veracity of
their contents. Any transfer or intent to transfer title or
ownership to petitioners or their predecessor were
also not shown.
○ As for the respondents’ evidence, the TCT, tax
declarations, and realty tax receipts were all in their
names and pursuant to Torrens System, a TCT enjoys
the conclusive presumption of validity and is the best
proof of ownership.
B2023(CARINO) - LAW 102, PROF. MIA GENTUGAYA