Iglesia Ni Cristo v. Ponferrada
REITERATIONFacts
The Antecedents: Plaintiffs, heirs of Enrique Santos, filed a complaint for Quieting of Title and/or Accion Reinvindicatoria against Iglesia Ni Cristo (INC). They alleged that Enrique Santos was the owner of a 936-square-meter land in Quezon City, covered by TCT No. 57272, and that they inherited the property and possessed it continuously. They claimed that the INC asserted ownership based on TCT No. 321744, which they asserted was invalid. They also alleged that the INC deprived them of the use and enjoyment of their property when they attempted to fence it in 1996. Procedural History: The INC moved to dismiss the complaint on grounds of non-compliance with verification and certification against forum shopping rules, prescription of the action, and other defects. The Regional Trial Court (RTC) denied the motion, holding that the signature of one heir, Enrique Santos, constituted substantial compliance, that prescription had not set in, and that the lack of plaintiffs' address was not a ground for dismissal. The Court of Appeals (CA) affirmed the RTC's ruling, finding that the RTC did not commit grave abuse of discretion. The Petition: The INC filed a Petition for Review on Certiorari before the Supreme Court, assailing the CA's decision, primarily on the issues of substantial compliance with the verification and certification requirements, the authority of Enrique Santos to represent the other heirs, and the prescription of the action.
Issue(s)
Whether the certification against forum shopping signed by only one of the plaintiffs constitutes substantial compliance with Section 5, Rule 7 of the 1997 Rules of Civil Procedure. Whether the authority of Enrique G. Santos to represent his co-heirs in filing the complaint is a matter of evidence. Whether the action for quieting of title and/or accion reinvindicatoria has prescribed.
Ruling
The petition is DENIED. The decision of the Court of Appeals in CA-G.R. SP No. 72686 is AFFIRMED.
Ratio Decidendi
On the issue of substantial compliance with the certification against forum shopping: The Court held that the CA did not err in affirming the application of the rule on substantial compliance. The plaintiffs, as heirs of the late Enrique Santos, have a common interest over the property as co-owners pro indiviso. In such cases, where there is a commonality of interest, the signature of one co-owner, who is a principal party and has sufficient knowledge of the facts, on the verification and certification against forum shopping is considered sufficient. This is in line with the principle that rules of procedure are established to secure substantial justice and should not be interpreted with absolute literalness to subvert their objective. The Court cited cases like Cavile v. Heirs of Cavile, Heirs of Agapito T. Olarte v. Office of the President of the Philippines, Gudoy v. Guadalquiver, and Dar v. Alonzo-Legasto where substantial compliance was applied due to commonality of interest. On the authority of Enrique G. Santos to represent his co-heirs: The Court found no necessity to show specific written authority. As co-owners of the subject property, each heir may properly bring an action for the recovery of possession or ownership, even without joining all other co-owners as co-plaintiffs, because the suit is deemed instituted for the benefit of all. The caption of the case, the opening statement of the complaint, the nature of the property ownership, and the verification signed by Enrique G. Santos stating he represents the heirs all support the validity of his representation. On the issue of prescription of action: The Court ruled that the action for quieting of title is imprescriptible until the claimant is ousted of possession. Even if the action is considered an accion reinvindicatoria, the prescriptive period had not commenced to run because the respondents (plaintiffs) were in actual and material possession of the property when they filed their complaint. The Court emphasized that an owner in actual possession of land may wait until their possession is disturbed or title is attacked before vindicating their right, as their undisturbed possession gives them a continuing right to seek judicial determination of adverse claims.
Main Doctrine
The rule on substantial compliance may be availed of with respect to the requirements of verification and certification against forum shopping when there is a commonality of interest among the plaintiffs, such as in cases of co-ownership, allowing one co-owner to sign on behalf of others. Furthermore, an action for quieting of title is imprescriptible until the claimant is ousted of possession, and an accion reinvindicatoria does not prescribe if the plaintiff remains in actual possession of the property.