Carreon v. Cartagena
REITERATIONFacts
The Antecedents: Petitioners filed a complaint to remove a cloud and quiet title over Lot No. 2642, a 213,083 square meter parcel of land. Respondents, in their answer, included a counterclaim to nullify petitioners' certificate of title, order them to vacate the land, and pay attorney's fees. Petitioners are the registered owners of Lot No. 2642, with their title originating from Feliciano Carreon. Respondents trace their rights to Antonio Maguinsawan, from whom they claim ownership. Respondents annotated an affidavit of adverse claim on petitioners' title, which was based on a Supreme Court decision (L-28332) allegedly adjudicating the lot in their favor. Petitioners, not parties to that case, claimed the decision was not effective against them. Procedural History: The Regional Trial Court ruled in favor of the defendants (respondents herein), declaring them owners of Lot No. 2642 and ordering the plaintiffs (petitioners herein) to convey the lot and pay costs. The Court of Appeals affirmed this decision. The Petition: Petitioners seek review of the Court of Appeals' decision, assigning several errors related to the dismissal of the counterclaim, jurisdiction, the validity of evidence, and the declaration of ownership.
Issue(s)
Whether the trial court erred in not dismissing the defendants-appellees' counterclaim for failure to state a cause of action regarding reconveyance and assertion of ownership. Whether the trial court erred in not dismissing the defendants-appellees' counterclaim for lack of jurisdiction due to failure to pay docket fees, considering it as a compulsory counterclaim. Whether the trial court erred in holding Exhibits "I-A" and "I-C" (alleged orders) to be fictitious, implying fraudulent procurement of title. Whether the trial court erred in holding Exhibits "7" and "7-A" (survey notification cards) to be hearsay evidence and improperly considering them as proofs of ownership, and whether these cards constitute declarations against interest. Whether the trial court erred in declaring the order adjudicating Lot 2642 in favor of the plaintiffs-appellants as null and void, and whether the respondents have a registerable right over Lot No. 2642. Whether the trial court erred in not holding that the defendants-appellees did not have any registerable right over Lot No. 2642, considering prior Supreme Court decisions and the acquisition history of the lot. Whether the trial court erred in not holding that the plaintiffs-appellants are legally entitled to the removal of the cloud on their title cast by the annotation of the defendants-appellees' affidavit of adverse claim, considering the validity of the respondents' claim.
Ruling
The petition is denied for lack of merit. The decision of the Court of Appeals affirming the judgment of the lower court is affirmed in toto, with double costs against petitioners. The decision is immediately executory.
Ratio Decidendi
On the counterclaim for reconveyance and assertion of ownership: The Court held that the respondents' answer with counterclaim sufficiently asserted ownership and alleged fraud, even without using the exact words "ownership" and "fraud." The allegations detailed the basis of their claim and questioned the validity of the petitioners' title, which was sufficient to state a cause of action. The respondents' claim of ownership was supported by documentary evidence, including the late Feliciano Carreon's own admissions in survey notification cards identifying the lot as belonging to the Heirs of Antonio Maguinsawan. Furthermore, a previous Supreme Court decision (G.R. No. L-28332) had confirmed the respondents' ownership, although petitioners were not parties to that case. The Court found that petitioners, as heirs of Feliciano Carreon, merely stepped into his shoes, and since Feliciano's title was allegedly fraudulently acquired, their title could also be cancelled and the property reconveyed. On the issue of jurisdiction and payment of docket fees for the counterclaim: The Court ruled that the counterclaim for reconveyance was a compulsory counterclaim, being necessarily connected with the subject matter of the complaint. Under the rules then in force, no docket fees were required for a compulsory counterclaim. Moreover, the petitioners voluntarily submitted to the jurisdiction of the trial court by participating in the proceedings and cannot later question its jurisdiction after an adverse judgment. Their objection was raised only after the trial in their memorandum, indicating a waiver of the issue. On the fictitious nature of Exhibits "I-A" and "I-C" and the fraudulent procurement of title: The Court affirmed the lower court's finding that the orders (Exhibits "I-A" and "I-C") upon which the decree of registration and subsequent title were based were fictitious. This conclusion was supported by the absence of the original orders in the cadastral case records, despite the existence of other orders from the same judge. The Court reasoned that if the orders were genuine, their originals should have been found in the records. The fact that Lot 2642 was still pending hearing in the cadastral case further indicated that the order adjudicating it was not genuine. The Court also noted that even if the order were genuine, it could be assailed for want of due process, as other claimants were not given an opportunity to be heard. On the admissibility and weight of Exhibits "7" and "7-A" (Survey Notification Cards): The Court found that these survey notification cards, made by Feliciano Carreon (petitioners' predecessor-in-interest), were properly appreciated as evidence of respondents' claim of ownership. In these cards, Feliciano Carreon identified Lot 2642 as belonging to the Heirs of Antonio Maguinsawan. The Court considered these entries as declarations against interest, which are admissible and carry significant weight as evidence. On the registerable right of respondents and the declaration of the order adjudicating Lot 2642: The Court upheld the findings that reconveyance was proper in favor of the respondents. The evidence showed that the lot was acquired by Antonio Maguinsawan in 1936, and respondents are his heirs. Feliciano Carreon's claim was derived from his brother Pantaleon, who had already transferred his rights to Antonio Maguinsawan. Therefore, Feliciano had no right to the property when he claimed it. The Supreme Court's decision in G.R. No. L-28332 further confirmed the respondents' ownership. On the registerable right of respondents considering prior Supreme Court decisions and acquisition history: The evidence showed that the lot was acquired by Antonio Maguinsawan in 1936, and respondents are his heirs. Feliciano Carreon's claim was derived from his brother Pantaleon, who had already transferred his rights to Antonio Maguinsawan. Therefore, Feliciano had no right to the property when he claimed it. The Supreme Court's decision in G.R. No. L-28332 further confirmed the respondents' ownership. On the removal of the cloud on title and the validity of the respondents' claim: Consequently, petitioners, as heirs of Feliciano, could not lawfully stake a claim, and their complaint to quiet title was correctly dismissed.
Main Doctrine
A fraudulently acquired title may be cancelled and the property reconveyed to the real owners, even if a transfer certificate of title has been issued to the heirs of the original registrant, as the heirs merely step into the shoes of the original registrant.