Caldito v. Obado
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns ownership of a 272.33 square meter portion of Lot No. 1633. The lot was originally declared for taxation in the name of Felipe Obado. After Felipe's death, Paterno Obado occupied the land and continued paying taxes. The petitioners, Spouses Jenestor and Maria Filomena Caldito, purchased the disputed portion from Antonio and Elena Ballesteros, who claimed ownership based on an Affidavit of Ownership. The respondents, Isagani and Gereon Obado, asserted that their father, Paterno, inherited the entire Lot No. 1633 from Felipe and that their family had been in open, peaceful, and uninterrupted possession of the whole property since 1969. 2. Procedural History: The petitioners filed a complaint for quieting of ownership and an injunctive writ against the respondents before the Regional Trial Court (RTC) of Laoag City. The RTC ruled in favor of the petitioners, upholding the validity of the sale and dismissing the respondents' claim. Upon appeal, the Court of Appeals (CA) reversed the RTC's decision, finding that the petitioners failed to prove the title of their predecessors-in-interest and that the Affidavit of Ownership lacked sufficient evidentiary support. The petitioners' motion for reconsideration was denied, leading to the present petition. 3. The Petition: The petitioners seek review on certiorari under Rule 45 of the Revised Rules of Court, assailing the CA's decision and resolution. They argue that they have proven ownership over the subject parcel of land. The core issue is whether the petitioners, through their predecessors-in-interest, the Spouses Ballesteros, established lawful title to the disputed portion of Lot No. 1633, considering the respondents' claim of inheritance and long-standing possession.
Issue(s)
Whether the petitioners were able to prove ownership over the subject parcel of land. Whether the petitioners have legal or equitable title to the subject parcel of land. Whether the Deed of Absolute Sale and Affidavit of Ownership executed by Antonio Ballesteros are sufficient to establish petitioners' claim.
Ruling
The petition is denied. The Decision of the Court of Appeals is affirmed.
Ratio Decidendi
On the issue of whether the petitioners were able to prove ownership over the subject parcel of land: The Supreme Court affirmed the Court of Appeals' ruling that the petitioners failed to prove ownership. The Court reiterated that an action to quiet title requires the plaintiff to have legal or equitable title to the property. The petitioners' claim was anchored on a Deed of Sale and an Affidavit of Ownership, but they failed to establish the title of their immediate predecessors-in-interest, the Spouses Ballesteros. The Court found Antonio's Affidavit of Ownership to be self-serving, lacking in specifics, and inadmissible as hearsay because Antonio was not presented as a witness. Furthermore, the affidavit was executed only a day before the sale, raising doubts about its probative value. The Court emphasized that litigation cannot be resolved by suppositions or presumptions without basis in evidence. On the issue of whether the petitioners have legal or equitable title to the subject parcel of land: The Court held that petitioners failed to prove equitable title or ownership. Their claim of legal title through the Deed of Sale and Affidavit of Ownership was insufficient because the title of their predecessors-in-interest, the Spouses Ballesteros, was not proven. The Court noted that the Affidavit of Ownership was not supported by documentary evidence and lacked specifics regarding the acquisition of the property and the alleged donations. The Court also pointed out that the tax declarations and receipts presented by the petitioners were of recent vintage and did not reflect payments made by their predecessors-in-interest. The Court stressed that tax declarations alone are not conclusive proof of ownership, but they can be basis for inferring possession. On the issue of whether the Deed of Absolute Sale and Affidavit of Ownership executed by Antonio Ballesteros are sufficient to establish petitioners' claim: The Court found these documents insufficient. The Affidavit of Ownership was deemed hearsay and inadmissible due to the affiant's absence as a witness. The Court also questioned the basis for claiming co-ownership among Felipe and his siblings, as no evidence established their relationship or that Felipe predeceased them. The Court noted that the subject lot was always declared in Felipe's name, and neither the Spouses Ballesteros nor Felipe's siblings had declared it in their names. The Court also highlighted that the Deed of Absolute Sale could not convey title because the Spouses Ballesteros themselves did not have title to the property. The Court further stated that for unregistered land, a buyer purchases at their peril, and good faith is not a defense if the seller lacks title. The petitioners' admission that respondents owned the bigger portion of Lot No. 1633 indicated they closed their eyes to facts that should have put them on guard.
Main Doctrine
A party seeking to quiet title must prove legal or equitable title to the property and that the deed, claim, encumbrance, or proceeding casting a cloud on the title is invalid or inoperative. Failure to prove the title of predecessors-in-interest renders the action for quieting of title dismissible. For unregistered lands, the buyer purchases at their peril, and good faith is irrelevant if the seller does not own the property.