MANANQUIL V.

MOICO (2012)
Topic: Quieting of titles – requisites
Presented by: Maria Analyn Ilagan
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CONCLUSION RULES
CONCLUSION ANALYSIS
CONCLUSION CONCLUSION
CONCLUSION

Whether or not the action for quieting of title over Lots 18 and 19 of petitioners Mananquil heirs
against respondent Moico is meritorious – NO

Whether or not the Court of Appeals can take cognizance of the possible violation of the NHA
contract (a matter not raised as issue in the RTC) vis-à-vis the ownership of the lots – YES

Petitioners Mananquil heirs filed an action for quieting of title against respondent Moico over two
parcels of land in Navotas.
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CONCLUSION

NCC 476 NCC 477 NCC 777

Action for quieting of Legal or equitable Transmission of rights
title title or interest to succession; death
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CONCLUSION ANALYSIS
CONCLUSION CONCLUSION
CONCLUSION

Property in dispute:
Lots 18 and 19 of NHA program “Tondo Dagat-Dagatan Foreshore Development Project”
located in Navotas
Petitioners: Respondent
“Mananquil Heirs”: Roberto Moico
Dionisio Mananquil, Laudencia Mananquil-
Villamor, Estanislao Mananquil, And Dianita
Mananquil-Rabino, Represented By Otillo
Rabino
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CONCLUSION RULES
CONCLUSION ANALYSIS
CONCLUSION CONCLUSION
CONCLUSION

Lot 18 & 19:

Lease
Lot 18: Conditional
Contract of Sale
Lot 19: purchase from
Third party
other grantee
Petitioners Mananquil
Heirs
Lot 18 & 19:
Sale
NHA program “Tondo Spouses Iluminardo &
Dagat-Dagatan Prescila Mananquil
Foreshore Development Respondent Moico
Project”
Maypa + 2 persons who
claim to be surviving heirs
of the spouses
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CONCLUSION RULES
CONCLUSION ANALYSIS
CONCLUSION CONCLUSION
CONCLUSION

• RTC: In favor of petitioners Mananquil heirs

Third party
• CA: In favor of respondent Moico Petitioners Mananquil
Heirs
• Petitioners Mananquil heirs failed to Eviction
show that Spouses Iluminardo and Action for
Prescilla have perfected their grant quieting of title
& injunction
from NHA.
• Lots 18 and 19 must still belong to NHA. Respondent Moico
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CONCLUSION RULES
CONCLUSION ANALYSIS
CONCLUSION CONCLUSION
CONCLUSION
Petitioners: Mananquil Heirs Respondent: Moico
On the propriety of CA’s actions:
• CA cannot touch on the alleged violation of the • CA was correct in taking cognizance of the
Spouses of their Conditional CTS with NHA alleged violation because the same is
• NHA did not intervene in the lower court inseparable with the issue of ownership of Lots
proceedings 18 and 19.
On the quieting of title:
• They are the legal heirs of Iluminardo Mananquil. • Mananquil heirs failed to prove their title or
As such, they possess the requisite legal or interest over Lots 18 and 19. It was Moico’s
equitable title or interest. They can file the civil predecessor (Eulogio Maypa) who paid all
action for quieting of title. liabilities to NHA who subsequently transferred
• Iluminardo’s rights were transferred to them upon the properties to Maypa.
his death, following NCC 777. Their interest as
successors-in-interest, even if imperfect, is enough
basis for an action for quieting of title
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CONCLUSION RULES
CONCLUSION ANALYSIS
CONCLUSION CONCLUSION
CONCLUSION
On the basis of Property law, Respondent Moico has stronger arguments because:

• In order for an action for quieting of title to prosper, the plaintiff must have legal or equitable title to, or interest in, the
property which is the subject matter of the action (Art. 477).
o Legal title – denotes registered ownership.
o Equitable title – denotes beneficial ownership.
o In the absence of such legal title or equitable title, or interest, there is no cloud over the property to be prevented or
removed.
• What is expected of the Court in settling an action for quieting of title?
o To determine the rights of all claimants, as follows:
• To place things in their proper place
• To make the person who has no rights over the property respect and not disturb the other party who does have
such rights
• What is the goal of an action for quieting of title? That all clouds over the property be extinguished so that the rightful
owner will be free to use the property as he deems best.
• What are the two indispensable requisites for an action for quieting of title?
1. The plaintiff has a legal or equitable title or interest in the real property; and
2. The deed, claim, encumbrance, or proceeding claimed by the plaintiff to be casting cloud on his property is in
fact invalid or inoperative, regardless of its prima facie appearance of validity or legal efficacy
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CONCLUSION RULES
CONCLUSION ANALYSIS
CONCLUSION CONCLUSION
CONCLUSION
On the basis of Property law, Respondent Moico has stronger arguments because:

• In this case, the issue of the award of the NHA grant determines the issue for the action of quieting of title.

o Mananquil heirs failed to establish their qualifications and right to succeed Iluminardo under the NHA program.
They failed to provide any documentation that Spouses Iluminardo and Prescilla indeed became the registered
owners and beneficiaries of Lots 18 and 19. They were unable to fulfill the first requirement.

o However, the CA’s assumption that Spouses Iluminardo and Prescilla have violated the contractual terms seems to be
speculative because there was no proof to support this conclusion.
• The RTC and CA should have required the Mananquil heirs to provide proofs of either (1) a certificate of title or
the like in favor of the Spouses, or (2) in the absence of the former, a right to succeed the Spouses not only as
heirs but also as successors/beneficiaries under the NHA program.