Quieting of title

An action for quieting of title is a remedy that determines the respective rights of conflicting claimants to a parcel of land in order to dissipate every cloud of doubt over the property and to stop the one who has no right over it from disturbing the real owner. What are the requisites for an action to quiet title? This is the issue answered in this case.

This case involves three parcels of agricultural land situated in the Bicol region owned by Siony and her late husband Fred. About 21 years ago, Siony sold said land to her nephew Jaime through a Deed of Absolute Sale. Since Jaime resided in Manila, he placed one parcel with an area of 3,495 square meters in the care of his brother Mario and his nephew Mandy, the son of Mario, on the condition that Mario and Mandy would religiously deliver the produce of said land. Unfortunately however, after eleven years of possession, Mario and Mandy failed and continuously refused to deliver the produce of the land and to vacate the same despite Jaime’s demands. So Jaime filed an action against Mario and Mandy for quieting of title, recovery of possession, rendition of accounting and damages.

In their defense, Mario himself admitted that their late Auntie Siony and Uncle Fred owned the land and he paid the taxes in their behalf. But he claimed that he and his son Mandy have been in open, continuous, peaceful, adverse and uninterrupted possession of subject land in the concept of owner, where their residential house was erected for almost 50 years; thus Jaime’s action was already barred by prescription or laches. They further claimed that the fact that they gave Jaime portions of the land’s produce was merely in keeping with the Filipino culture of sharing blessings with siblings and relatives. They also argued that the deed of absolute sale presented by Jaime is not the legal or beneficial title contemplated in the law for quieting of title under Article 476 of the Civil Code.

After trial, the Regional Trial Court (RTC) rendered judgment declaring Jaime as the owner of the subject land and directed Mario and Mandy to immediately relinquish and surrender possession thereof to Jaime. It ruled that Jaime had a better right over the land as proven by the deed of absolute sale executed in his favor which was notarized, and therefore enjoys the presumption of regularity, while Mario and Mandy’s possession is not in the concept of an owner.

On appeal by Mario and Mandy, the Court of Appeals (CA) reversed the RTC decision and ruled that the notarized deed of sale executed in Jaime’s favor did not transfer the land’s ownership to him, given that he was never placed in possession and control thereof. Moreover, the CA debunked Jaime’s claim that he is a buyer in good faith since the subject land was not in the possession of Siony and he failed to prove and clarify the true nature of Siony’s possession.

Was the CA correct?

The Supreme Court said that contrary to the position taken by the CA, it finds that Jaime satisfactorily established his equitable title over the subject land and to the removal of cloud of doubt thereon, particularly the claim of Mario and Mandy that they are the owners thereof. Equitable title is the title derived through a valid contract or relation and based on recognized equitable principles; the right of the party to whom it belongs, to have the legal title transferred to him. In this case, Jaime’s title to the subject land was derived through a deed of sale as evidenced by a notarized document whereby Siony, the widow of Fred, transferred the subject land and two other parcels to Jaime. Siony’s right to transfer the land to Jaime was clearly established during the trial as Mario himself admitted.

The execution of the notarized deed of absolute sale constitutes constructive delivery as to effect the transfer of ownership from the seller to the buyer (Article 1498 Civil Code). In this case, Jaime exercised possession of said land through Mario and eventually his son Mandy, whom he allowed to stay and care for the land in exchange for the delivery of the produce thereof. The fact that Mario delivered the produce of the land to Jaime was also admitted by Mario. So the action for quieting of title should prosper to benefit the heirs of Jaime, who already died (Heirs of Extremadura etc. vs. Extremadura etc., G.R. 211065, June 15, 2016).