Tandog v. Macapagal
REITERATIONFacts
The Antecedents: Petitioners claim ownership and possession of a 147,991 square meter land in Antipolo City since time immemorial, tracing their rights to Casimiro Policarpio. They discovered that portions of the land were occupied by respondents Spouses Calderon and Renato Macapagal. Petitioners alleged that the Calderons used falsified documents for their 20,116 square meter claim, which they sold to the government. Macapagal obtained Free Patent No. 045802-1165, leading to Original Certificate of Title (OCT) No. P-665 for 18,787 square meters. Procedural History: Petitioners filed a complaint for quieting of title. The Spouses Calderon denied the allegations, asserting their purchase and possession since 1958. Before trial, petitioners and Macapagal entered into a Compromise Agreement, acknowledging Macapagal's ownership over his titled portion, which the trial court approved. The Spouses Calderon filed a demurrer to evidence, which the trial court granted, dismissing the complaint. Petitioners appealed to the Court of Appeals, which affirmed the trial court's dismissal. The Petition: Petitioners contend that the Spouses Calderon's claim of purchase and Macapagal's claim of applying for a Free Patent constitute judicial admissions that cast a cloud upon their interest in the property. They seek review of the Court of Appeals' decision.
Issue(s)
Whether the allegations of respondents regarding their purchase of the property and application for a Free Patent constitute judicial admissions that cast a cloud upon petitioners' interest in the disputed property. Whether the Court of Appeals erred in affirming the trial court's dismissal of the complaint for quieting of title.
Ruling
The petition is denied, and the assailed Decision of the Court of Appeals is affirmed. Costs are against the petitioners.
Ratio Decidendi
On the issue of whether the allegations of respondents constitute judicial admissions casting a cloud on petitioners' interest: The Court held that for an action to quiet title, the claimant must show an instrument, record, claim, encumbrance, or proceeding that casts a cloud on the owner's title or interest. The Court reiterated the principle that the grounds for such an action are exclusive, as per the maxim 'expresio unius est exclusio alterius'. Petitioners failed to present evidence to substantiate their claim that the documents relied upon by the respondents were falsified. Furthermore, the alleged falsified documents were merely marked as exhibits but were never formally offered in evidence, rendering them without evidentiary value. The Court emphasized that evidence must be formally offered to be considered by the court, citing Section 34 of Rule 132 of the Rules of Court and jurisprudence. On the issue of whether the Court of Appeals erred in affirming the dismissal of the complaint: The Court found that petitioners failed to establish their legal or equitable title to the property. They did not present sufficient evidence to prove the existence of Casimiro Policarpio as their predecessor-in-interest or the hereditary link between him and the petitioners. The testimonies presented were deemed hearsay and unreliable regarding the existence of Casimiro Policarpio and the claimed hereditary succession. The Court noted that to prove pedigree by acts or declarations of relatives, specific requisites under Section 39 of the Revised Rules of Evidence must be met, which petitioners failed to satisfy. Therefore, the dismissal of the complaint was proper.
Main Doctrine
A complaint for quieting of title requires the claimant to show an instrument, record, claim, encumbrance, or proceeding that casts a cloud on the owner's title or interest. Documents merely marked as exhibits but not formally offered in evidence cannot be considered as evidence. Furthermore, to establish a claim based on inheritance, the existence of the predecessor-in-interest and the hereditary link must be proven with evidence, satisfying the requisites for declarations about pedigree.