Basa v. Loy
REITERATIONFacts
The Antecedents: This case concerns a dispute over a 496-square meter residential lot in Baguio City, originally titled under Busa Carantes, predecessor-in-interest to Manuel and Robert Carantes. The property was mortgaged in 1994 to respondent Angeline Loy, who subsequently foreclosed on the mortgage and emerged as the highest bidder at the auction sale. After consolidating ownership, Loy obtained a writ of possession in March 2006. Petitioners, comprised of four sets of spouses, claim that in 1992 and 1993, they purchased portions of this lot, totaling 351 square meters, from respondent Robert Carantes via deeds of sale and took possession of these portions. They assert that the title issued to Angeline Loy creates a cloud on their ownership. Procedural History: The petitioners filed a petition for quieting of title with a prayer for injunctive relief and damages before the Regional Trial Court (RTC) of Baguio City, Branch 7, docketed as Civil Case No. 6280-R. They sued Angeline Loy, Robert Carantes, the Register of Deeds, and the City Sheriff and Assessor's Office. The RTC denied the admission of the petitioners' documentary evidence (photocopied deeds of sale) due to the failure to present original copies, and because Robert Carantes, the purported seller, was not presented to testify on his affidavit. Consequently, the RTC dismissed the petition for failure to discharge the burden of proof. The petitioners' motion for reconsideration was denied. Upon appeal, the Court of Appeals (CA) affirmed the RTC's decision, holding that the petitioners failed to prove their case by a preponderance of evidence and that the trial court did not err in disallowing the photocopied deeds and the affidavit without the affiant's testimony. The CA also denied the petitioners' subsequent motion for reconsideration. The Petition: The petitioners are now before the Supreme Court via a Petition for Review on Certiorari under Rule 45, seeking to set aside the CA's decision. They argue that they have adequately proven their ownership through possession, that the lower courts disregarded substantive law in favor of technicalities by refusing to consider the original deeds of sale attached to their motion for reconsideration, and that Angeline Loy was a buyer in bad faith. They contend that their prior unrecorded sale should prevail over a subsequent mortgage. The lone issue presented is whether they have proven their case for quieting of title by preponderant evidence.
Issue(s)
Whether petitioners have proved, by preponderant evidence, their case for quieting of title, considering their presented evidence. Whether the lower courts erred in denying the admission of the deeds of sale for failure to present the original copies, and the admissibility of subsequent submissions and testimonies.
Ruling
The Petition is denied. The assailed dispositions of the Court of Appeals are affirmed.
Ratio Decidendi
On the issue of whether petitioners have proved, by preponderant evidence, their case for quieting of title: For an action to quiet title to prosper, two indispensable requisites must concur: (1) the plaintiff or complainant must have legal or equitable title to, or interest in, the real property subject of the action; and (2) the deed, claim, encumbrance, or proceeding claimed to be casting a cloud on the title must be shown to be in fact invalid or inoperative despite its prima facie appearance of validity or legal efficacy. Legal title denotes registered ownership, while equitable title means beneficial ownership. In this case, the petitioners failed to establish their legal or equitable title to the disputed portions of the property. Their claim of ownership was based on purported deeds of sale, but they failed to present the original copies of these documents as required by the Best Evidence Rule. The Court emphasized that possession of the property does not necessarily prove title, as it could be by lease or mere tolerance. Without adequately proving their title or right to the disputed portions, their case for quieting of title could not prosper. On the issue of whether the lower courts erred in denying the admission of the deeds of sale for failure to present the original copies: The Supreme Court affirmed the RTC and CA's ruling that the petitioners failed to comply with the Best Evidence Rule. The RTC denied the admission of the photocopied deeds of sale because the originals were not submitted. Petitioners' attempt to submit the original deeds of sale with their motion for reconsideration was also denied, as they failed to show that their failure to present the originals during trial fell within the exceptions provided under Section 3, Rule 130 of the Rules of Court. The Court noted that the petitioners' counsel had manifested that they reserved the right to present the original deeds, and the Branch Clerk of Court had provisionally marked the photocopies subject to the submission of the originals. Furthermore, the Court found that one of the documents appended to the motion for reconsideration was different from what was presented during the ex parte hearing. The Court also highlighted that the testimonies of petitioners' witnesses contradicted Robert Carantes' affidavit regarding the areas allegedly sold and the price per square meter, rendering the evidence unsatisfactory and inconclusive. The unnotarized deed of sale in favor of the Basa spouses could not stand without corroboration, especially since Robert Carantes' affidavit was rendered inadmissible due to his failure to testify thereon.
Main Doctrine
For an action to quiet title to prosper, the plaintiff must have legal or equitable title to, or interest in, the property, and must prove that the deed, claim, encumbrance, or proceeding casting a cloud on the title is invalid or inoperative. Failure to present original documents as required by the Best Evidence Rule, without valid exceptions, is fatal to the claim.