Esguerra v. Manantan
REITERATIONFacts
The Antecedents: Petitioner Franco Esguerra claims ownership of a parcel of land inherited from his father, Pio Esguerra, who in turn inherited it from his father, Lorenzo Esguerra. Pio had allowed Gaudencio Miguel to occupy the property and mortgaged it to him via a "Deed of Sale with Right to Repurchase" dated June 6, 1960. Respondents Alfonso Manantan, Danilo Manantan, Ariang Antonio, Aquilino Concepcion, and Fortunato Miguel constructed their houses on the lot without Pio's knowledge or consent. In 1979, Gaudencio executed a "Kasunduan" to cancel the deed of sale with right to repurchase. Franco applied for and was issued a free patent and subsequently an Original Certificate of Title (OCT) No. P-15176 in his name. Procedural History: Franco filed an ejectment case against the respondents. Pending this case, the respondents filed a case for annulment of Franco's OCT, which was consolidated with the ejectment case. The Regional Trial Court (RTC) dismissed the ejectment case and declared OCT No. P-15176 null and void. The Court of Appeals (CA) affirmed the RTC decision. The Petition: Franco filed a petition for review on certiorari, assailing the CA's decision and resolution. He argued that he was not estopped from questioning the RTC's jurisdiction, that respondents had not acquired a vested right, that his right to redeem had not expired, and that his claim for fees was valid. The Supreme Court considered the issues of estoppel and the better right to the property.
Issue(s)
Whether petitioner Franco Esguerra is estopped from questioning the jurisdiction of the RTC. Whether respondents' action for annulment of title had prescribed. Whether the subject land is private property and whether respondents acquired ownership through acquisitive prescription. Who has a better right over the contested property, considering the nature of the 1960 Deed of Sale and the validity of Franco Esguerra's title.
Ruling
The petition is PARTIALLY GRANTED. The Court declared petitioner Franco Esguerra a co-owner and holder of imperfect title over Lot No. 661. Free Patent No. 034914-92-1117 and Original Certificate of Title No. P-15176 in the name of Franco Esguerra were declared null and void.
Ratio Decidendi
On the issue of estoppel: The Supreme Court affirmed the appellate court's finding that petitioner was estopped from questioning the jurisdiction of the RTC. While lack of jurisdiction cannot generally be waived, participation in all stages of the proceedings, including invoking the court's authority for affirmative relief, bars a party from challenging jurisdiction by estoppel. Petitioner himself filed the ejectment case, and although respondents initially moved to dismiss for lack of jurisdiction, both parties later moved for a joint trial. Crucially, petitioner never raised the issue of lack of jurisdiction before the RTC, only asserting it for the first time before the Court of Appeals, which demonstrated an inconsistent posture after voluntarily submitting to the court's authority. This submission and participation effectively estops him from later attacking the jurisdiction he invoked. On the issue of prescription for annulment of title: The Court held that the action for annulment of title had not prescribed. The one-year prescriptive period for fraud does not apply when the person seeking annulment is in possession of the lot, as the action then partakes of a suit to quiet title, which is imprescriptible. Since the respondents were in possession of the lot, their action to annul OCT No. P-15176 was not barred by prescription. On whether the subject land is private property and whether respondents acquired ownership through acquisitive prescription: The Supreme Court found that the subject land is private property. The Court also found that respondents' possession did not ripen into ownership through acquisitive prescription because they occupied the property by permission and later agreed to pay rent, thus becoming mere lessees, not owners. Their possession was not in the concept of an owner. On who has a better right over the contested property, considering the nature of the 1960 Deed of Sale and the validity of Franco Esguerra's title: The Court noted that the "Deed of Sale with Right to Repurchase" dated June 6, 1960, between Pio Esguerra and Gaudencio Miguel, constituted an equitable mortgage under Article 1602(6) of the Civil Code, as evidenced by Pio's continued declaration of the property for tax purposes and Gaudencio's subsequent acknowledgment of the mortgaged nature of the transaction. Therefore, Pio's ownership did not cease, and the period of redemption under Article 1606 did not apply. Consequently, the free patent and OCT issued to Franco were null and void as they were issued over private land. However, Franco's claim of ownership was deemed imperfect and subject to confirmation of title.
Main Doctrine
A free patent issued over private land is null and void. Possession with a juridical title, not in the concept of an owner, cannot ripen into ownership by acquisitive prescription. A party who voluntarily submits to the jurisdiction of a court is estopped from later questioning it.