Heirs of Ramos v. Bagares
REITERATIONFacts
The Antecedents: Respondents Prosalita and Danton Bagares alleged that they purchased a 3,000-square meter parcel of land (Lot No. 12020) from the late Basilia Galarrita-Naguita on July 24, 1995. This property was a portion of Basilia's larger landholdings. Aquilino Ramos subsequently filed a free patent application for Lot No. 12020, submitting a Deed of Sale of Unregistered Land. Respondents opposed this, claiming Aquilino tampered with the deed by changing the lot number from 12019 to 12020. The DENR denied Aquilino's free patent application. Petitioners Marilou, Benjamin, Elyer, and Lydia were buyers of a portion of Lot No. 12020 from Aquilino, claiming possession since 1978. They asserted their predecessor-in-interest did not tamper with the deed and that their possession was continuous. Procedural History: Respondents filed a complaint for Declaration of Nullity of Tampered Deed of Sale of Unregistered Land. The Regional Trial Court (RTC) ruled in favor of respondents, declaring the Deed of Sale void, canceling tax declarations made through it, and ordering defendants to pay attorney's fees. The Court of Appeals (CA) affirmed the RTC decision, giving weight to the DENR's findings of tampering and considering Aquilino's alleged admission during barangay conciliation as a judicial admission. The CA also ruled that petitioners' adverse possession fell short of the requirements for acquisitive prescription and that the defense of good faith was inapplicable to unregistered land. The Petition: Petitioners (Heirs of Aquilino Ramos and Marilou, Benjamin, Elyer Galarrita) filed petitions for review on certiorari, arguing that the deed of sale was identifiable despite the lot number alteration, that no forgery was alleged, that ambiguities were resolved by an Affidavit of Confirmation of Sale, that their sketch/survey plans showed their possessed property matched the deed, and that prescription had set in. They also argued they were buyers in good faith and their construction of a house was in good faith.
Issue(s)
Whether the Court of Appeals erred in affirming the Regional Trial Court's Decision. Whether the Deed of Sale of Lot No. 12020 is null and void for having been tampered with. Whether prescription had already set in in favor of the petitioners. Whether the petitioners were buyers in good faith.
Ruling
The Supreme Court denied the consolidated petitions for review on certiorari. The Court affirmed the Decision of the Court of Appeals with the modification that the award of attorney's fees is deleted. The Court found that the petitions raised factual issues beyond the scope of a Rule 45 appeal and that petitioners failed to show reversible error on the part of the CA.
Ratio Decidendi
On the issue of whether the Court of Appeals erred in affirming the Regional Trial Court's Decision: The Court held that a petition for review on certiorari under Rule 45 is limited to questions of law, and the issues raised by the petitioners concerning the tampering of the deed of sale, prescription, and good faith are factual matters. The Court found no cogent reason to overturn the RTC's findings, as affirmed by the CA, that the Deed of Sale was void due to tampering. The CA's reliance on the DENR's findings and Aquilino Ramos's admission during barangay conciliation as a judicial admission was deemed proper. The Court reiterated that trial court findings of fact, especially when sustained by the appellate court, are entitled to great weight and will not be disturbed on appeal. On the issue of whether the Deed of Sale of Lot No. 12020 is null and void for having been tampered with: The Court affirmed the CA's finding that the Deed of Sale was void. This was based on the DENR's findings that Aquilino Ramos submitted a tampered document in his free patent application, which Aquilino failed to rebut. Furthermore, Aquilino's admission during barangay conciliation proceedings that he tampered with the deed of sale qualified as a judicial admission under Section 4, Rule 129 of the Rules of Court. A tampered deed of sale is void and cannot transfer ownership, as the seller, Aquilino Ramos, had no title or interest to transfer. On the issue of whether prescription had already set in in favor of the petitioners: The Court rejected the argument that ownership was acquired by prescription. For ordinary acquisitive prescription, possession must be in good faith and with just title, which was not proven. For extraordinary acquisitive prescription, 30 years of uninterrupted adverse possession is required. The Court noted that when the case was filed in 2004, petitioners had been in possession for only 26 years (from 1978), falling short of the 30-year requirement. The subject land was also unregistered. On the issue of whether the petitioners were buyers in good faith: The Court ruled that the defense of having purchased property in good faith is applicable only to registered land, where a buyer can rely on the clear title of the registered owner. Since the subject property was unregistered land, petitioners Marilou, Benjamin, and Elyer could not claim to be buyers in good faith, as they had no notice that the seller lacked the capacity to sell. The Court also pointed out several procedural infirmities in the petitions, including lack of material dates, proof of service, and proper verification, which further warranted their denial.
Main Doctrine
A deed of sale found to be tampered with is void and cannot transfer ownership. The defense of good faith in purchasing unregistered land is unavailing. Possession for 26 years falls short of the 30-year requirement for extraordinary acquisitive prescription. Awards of attorney's fees require clear factual, legal, and equitable justification.