Heirs of Deloy v. Basa-Joaquin
REITERATIONFacts
The Antecedents: The underlying dispute concerns the ownership of several parcels of land originally part of Lot No. 4012, registered under Transfer Certificate of Title (TCT) No. T-13784 in the names of siblings Dionisio Deloy and Isabel Deloy. Following a subdivision of Lot No. 4012 and a reconstitution of the original title due to a fire, various new titles were issued, including TCT Nos. T-19127 and T-19128 in the name of the Province of Cavite. These titles were later declared null and void by the Regional Trial Court (RTC) and affirmed by the Court of Appeals (CA) in an earlier case concerning the annulment of Torrens titles. Subsequently, other titles derived from the reconstituted TCT No. (T-13784) RT 12612, specifically TCT Nos. T-19312, T-19313, and T-19314, were cancelled and new titles were issued in the names of Verna Basa-Joaquin, the Heirs of Spouses Mariano Del Rosario and Macaria Guevarra, and the Heirs of Maxima Guevarra, purportedly based on prior sales from Dionisio Deloy. The Heirs of Spouses Deloy later obtained new titles for these same lots after the settlement of the Estate of Spouses Deloy, leading to conflicting claims. Procedural History: The present case originated from separate petitions for quieting of title filed by Verna Basa-Joaquin (Sp. Proc. Case No. TMSCA-005-08) and the Heirs of Spouses Mariano Del Rosario and Macaria Guevarra along with the Heirs of Maxima Guevarra (Sp. Proc. Case No. TMSCA-0008-07) before the RTC. The RTC ruled in favor of the respondents, declaring their titles valid and subsisting and ordering the cancellation of the titles held by the Heirs of Spouses Deloy. The Heirs of Spouses Deloy appealed this decision to the CA. The CA affirmed the RTC's joint decision. Aggrieved, the Heirs of Dionisio Deloy and Praxedes Martonito Deloy, as represented by Policarpio M. Deloy, the City Assessor of Trece Martires City, and the Register of Deeds for the City of Trece Martires, filed the instant Petition for Review on Certiorari. The Petition: The petitioners, the Heirs of Dionisio Deloy and Praxedes Martonito Deloy, are seeking a review of the Court of Appeals' decision affirming the RTC's ruling that favored the respondents. The petition raises three main issues: (1) whether the CA erred in finding that the respondents substantially complied with the requirement of a certificate of non-forum shopping; (2) whether the CA erred in upholding the RTC's denial of the petitioners' motion for a new trial, which was based on their alleged failure to receive notices of hearings; and (3) whether the CA erred in affirming the RTC's ruling to grant the respondents' petitions to quiet title, arguing that the respondents failed to prove their ownership over the disputed lots.
Issue(s)
Whether the CA erred in finding that respondents substantially complied with the requirement of a certificate of non-forum shopping. Whether the CA erred in upholding the RTC's denial of petitioners Heirs of Spouses Deloy's motion for new trial. Whether the CA erred in affirming the RTC's ruling to grant respondents' petitions to quiet title.
Ruling
The Supreme Court granted the petition, reversed and set aside the Decision and Resolution of the Court of Appeals, and dismissed the petitions for quieting of title filed by the respondents. The Court found that the respondents failed to prove by preponderance of evidence that they validly acquired ownership over Lot Nos. 4012-J, 4012-K, and 4012-L.
Ratio Decidendi
On Issue 1 (Substantial Compliance with Certificate of Non-Forum Shopping): The Court held that the respondents substantially complied with the requirement of a certificate of non-forum shopping. While the SPAs authorizing Maurino and Angelita to sign the verification and certification were submitted belatedly, the Court has consistently ruled that such belated submission constitutes substantial compliance. The Court emphasized that rules on verification and forum shopping should not be interpreted with absolute literalness to the detriment of the orderly administration of justice. The requirement of strict compliance underscores its mandatory nature, but it does not mean that its requirements can be completely disregarded. The belated submission of proof of authority, as in this case, is not fatal to the cause of the respondents. On Issue 2 (Denial of Motion for New Trial): The Court agreed with the RTC's denial of the Heirs of Spouses Deloy's motion for new trial. The RTC had declared the petitioners in default due to their repeated failure to appear in court. The grounds for a new trial, such as fraud, accident, mistake, or excusable negligence, were not sufficiently established. The Court found no extrinsic or collateral fraud, as the petitioners did not allege that the respondents prevented their participation or that their counsels betrayed them. Furthermore, the petitioners failed to expound on how their purported failure to receive notices qualified as accident or mistake, and they did not allege personal negligence. The claim of violation of due process due to failure to receive notices was not adequately proven, especially since one of their counsels received notice of the order precluding them from presenting evidence, and notice to one counsel is notice to all. The petitioners also failed to move to set aside the order of default. On Issue 3 (Petitions to Quiet Title): The Court found that the respondents failed to prove that their petitions to quiet title were meritorious. An action to quiet title requires the plaintiff to have legal or equitable title and that the cloud on the title be shown to be invalid or inoperative. While the respondents presented TCTs for Lot Nos. 4012-J, 4012-K, and 4012-L, these titles were derived from a void reconstituted title. Verna Basa-Joaquin failed to present documentary proof of the sale of Lot No. 4012-J from Dionisio to her parents or from her parents to herself, admitting there was no such proof. The tax declarations presented were not conclusive evidence of ownership, especially when real property taxes were paid much later than the supposed purchase date. Similarly, the evidence for the sale of Lot Nos. 4012-K and 4012-L was found wanting, with the Deeds of Absolute Sale not appearing in the records and tax declarations not being conclusive proof of ownership. The Court concluded that the respondents were unable to prove that their predecessors-in-interest validly purchased the lots from Dionisio, rendering their petitions for quieting of title without basis.
Main Doctrine
The Supreme Court reversed the Court of Appeals, holding that the respondents failed to prove by preponderance of evidence that they validly acquired ownership over the disputed lots, thus their petitions for quieting of title were dismissed. The Court also found that the respondents' belated submission of proof of authority to sign the verification and certification against forum shopping constituted substantial compliance. Furthermore, the denial of the petitioners' motion for new trial was upheld due to their failure to establish grounds for fraud, accident, mistake, or excusable negligence.