Mactan Cebu International Airport Authority v. Heirs of Gavina Ijordan
REITERATIONFacts
The Antecedents: On October 14, 1957, Julian Cuizon (Julian) executed a Deed of Extrajudicial Settlement and Sale (Deed) covering Lot No. 4539 in favor of the Civil Aeronautics Administration (CAA), the predecessor-in-interest of the Mactan Cebu International Airport Authority (MCIAA). Julian represented himself as the sole heir of the deceased owner, Pedro Cuizon. However, the lot was actually co-owned by several other heirs. In 1980, the other heirs (Respondents) successfully petitioned for the judicial reconstitution of the original certificate of title, resulting in the issuance of Original Certificate of Title (OCT) No. RO-2431 in the names of all the heirs, including Julian. The Respondents asserted they never authorized Julian to sell their respective shares to the Government. Procedural History: MCIAA filed a complaint for the cancellation of the Respondents' title, alleging that the lot had been sold to the Government in 1957 and that it had been in continuous possession since then. After MCIAA presented its evidence, the Respondents filed a Demurrer to Evidence, arguing that the Deed was a mere photocopy and that the sale was unenforceable against them for lack of consent. The Regional Trial Court (RTC) granted the demurrer with qualification, dismissing the complaint as to the Respondents' shares but recognizing MCIAA as the owner of Julian's 1/22 share. The Court of Appeals (CA) affirmed the RTC's ruling in its entirety. The Appeal: MCIAA filed a Petition for Review on Certiorari under Rule 45, arguing that the Respondents' inaction for over 30 years constituted implied ratification of the sale and that they were guilty of laches. MCIAA further contended that its continuous possession since 1957 entitled it to ownership through acquisitive prescription, and that the Respondents only asserted their rights due to the rising land values in Mactan.
Issue(s)
Whether the sale of the entire lot by Julian Cuizon was valid and binding against his co-heirs. Whether the Respondents are barred by laches or estoppel from impugning the 1957 sale. Whether MCIAA acquired ownership of the entire lot through acquisitive prescription.
Ruling
The Supreme Court DENIED the petition and AFFIRMED the decision of the Court of Appeals.
Ratio Decidendi
On Issue 1: The Court ruled that the sale was unenforceable against the Respondents. Applying Article 1317 of the Civil Code, no person may contract in the name of another without being authorized or having a legal right to represent them. Since Julian Cuizon sold the entire property without the consent or authority of his co-heirs, the sale only affected his undivided 1/22 share. The Court emphasized that a co-owner's disposition of the entire property only transfers the portion that would correspond to him in the partition. Consequently, the Deed had no legal effect on the shares of the other co-owners who did not participate in the transaction. On Issue 2: The Court held that the Respondents were not guilty of laches or estoppel. Estoppel, under Article 1439 of the Civil Code, applies only to those who were parties to the contract and their privies. Because the Respondents were not parties to the 1957 Deed and the contract was declared unenforceable as to their shares, there was no valid contract for them to ratify. The Court found no evidence of implied ratification, noting that the Respondents asserted their ownership by reconstituting their title in 1980. The delay in challenging the sale was excused by the fact that the sale was not registered and the Respondents were unaware of the transaction. On Issue 3: The Court rejected the claim of acquisitive prescription. It is a fundamental principle under the Torrens System that no adverse possession can deprive a registered owner of their title by prescription. Citing Francisco v. Rojas, the Court reiterated that the purpose of the Torrens System is to quiet title to land and stop any question as to its legality forever. Once a title is registered, the owner may rest secure without the fear of losing the land to an adverse possessor. Since the Respondents held a valid Torrens title, MCIAA's alleged possession since 1957, even if proven, could not ripen into ownership.
Main Doctrine
Under Article 1317 of the Civil Code, a contract entered into in the name of another by one who has no authority or legal representation is unenforceable, unless ratified. In the context of co-ownership, a sale by one co-owner of the entire property without the consent of the others only transfers the seller's undivided interest. Additionally, the principle of indefeasibility of a Torrens title ensures that registered land cannot be acquired by prescription or adverse possession, as the system's purpose is to quiet title to land forever.