Republic v. Dignos-Sorono
REITERATIONFacts
The Antecedents: Lot Nos. 2296 and 2316 were adjudicated in 1929 to four parties in equal shares. The heirs of Tito Dignos, one of the adjudicatees, sold the entire two lots to the Civil Aeronautics Administration (CAA) in 1957 without the knowledge of the respondents, who are predecessors-in-interest of the other ¾ portion. In 1996, MCIAA, CAA's successor, erected a security fence and relocated families on Lot No. 2316. MCIAA also obtained tax declarations for the lots. Respondents filed a Complaint for Quieting of Title and Legal Redemption, alleging that the tax declarations cast a cloud on their titles and that they never sold their shares. They also claimed they were not notified of the sale of Tito Dignos' share. Procedural History: The Regional Trial Court (RTC) ruled in favor of the respondents, declaring the tax declarations void, the sale ineffective as to respondents' shares, and ordering MCIAA to resell Tito Dignos' ¼ share to respondents for P640.00. The RTC found that respondents and their predecessors were in continuous possession and were only disturbed in 1996. It held that registered lands cannot be subject to acquisitive prescription, that actions for quieting of title by possessors do not prescribe, and that laches did not apply because respondents only learned of the sale in 1996. The RTC also found the registration of the sale under Act No. 3344, instead of Act No. 496, ineffective as constructive notice. The Court of Appeals affirmed the RTC's decision. The Petition: MCIAA, through the Republic, assailed the Court of Appeals' decision, arguing that respondents no longer had the right to recover the lots due to the prior sale to the government and on the equitable grounds of estoppel and laches.
Issue(s)
Whether the sale of the entire lots by one co-owner without the consent of the other co-owners is valid. Whether MCIAA acquired ownership of the lots through acquisitive prescription. Whether respondents' action for quieting of title and legal redemption is barred by prescription and laches. Whether the redemption price should be based on the purchase price or the prevailing market value.
Ruling
The petition is denied. The Court of Appeals' decision affirming the RTC's ruling is upheld.
Ratio Decidendi
On the validity of the sale by a co-owner: The Court reiterated the principle that each co-owner has the full ownership of his part and may alienate it. Applying Article 493 of the Civil Code and jurisprudence, a sale of the entire property by one co-owner without the consent of the others is not null and void. Instead, it affects only the seller's undivided share, making the buyer a co-owner. Therefore, the CAA, petitioner's predecessor-in-interest, acquired only the ¼ undivided share of Tito Dignos' heirs. On acquisitive prescription: The Court affirmed the RTC's discrediting of MCIAA's claim of ownership by acquisitive prescription. The fact that the lots were registered, as evidenced by the stipulation regarding the reconstitution of titles and the issuance of a decree, meant they were covered by the Torrens system. Registered lands cannot be the subject of acquisitive prescription. Furthermore, the Extrajudicial Settlement and Sale itself indicated that the lots were covered by a cadastral case and a decree, implying they were registered properties. On prescription and laches: The Court found the RTC's discrediting of MCIAA's defenses of laches and prescription to be well-taken. Actions for quieting of title generally do not prescribe if the plaintiffs are in possession of the property, as the respondents were. Regarding laches, the respondents only became aware of the sale in 1996, negating any undue delay. Moreover, the registration of the deed of sale under Act No. 3344, which governs unregistered properties, was improper for registered lands and thus did not constitute constructive notice to the respondents. On the redemption price: The Court upheld the RTC's ruling that the redemption price should be based on the actual purchase price paid by the CAA for Tito Dignos' ¼ share, as provided by Article 1088 of the Civil Code. The law mandates reimbursement of the price of the sale. Although the Court took judicial notice of the increase in value, the absence of written notice of the sale to the respondents meant the redemption period had not yet lapsed. The Court also noted that the stipulation in the sale warranted the vendee against claims, implying MCIAA could seek recourse against the vendors-heirs.
Main Doctrine
A co-owner is entitled to sell his undivided share, and a sale of the entire property by one co-owner without the consent of the other co-owners is not null and void, but only affects the rights of the co-owner-seller, making the buyer a co-owner. Registration of a deed relating to registered land under Act No. 3344, instead of Act No. 496, does not operate as constructive notice to the whole world.