ASG Law

Tag: Torrens title

  • Upholding Co-Ownership: Partition Rights and the Limits of Torrens Titles Among Heirs

    In the case of Heirs of Feliciano Yambao v. Heirs of Hermogenes Yambao, the Supreme Court affirmed the imprescriptible right of co-owners to demand partition, even when one co-owner obtains a Torrens title over the shared property. The Court emphasized that obtaining a title under such circumstances creates an implied trust, preventing the titling co-owner from repudiating the co-ownership. This decision clarifies that a Torrens title does not automatically extinguish the rights of other co-owners, especially when the applicant acknowledges the co-ownership’s origins. This ensures that the rights of all heirs are protected, preventing unjust enrichment and upholding the principles of equity and fairness in property disputes.

    Family Land Disputes: When a Title Doesn’t Erase Shared Heritage

    The dispute revolves around a parcel of land in Barangay Bangan, Botolan, Zambales. Originally possessed by Macaria De Ocampo, the land was managed by her nephew, Hermogenes Yambao. After Hermogenes died, his heirs enjoyed communal use of the land until the heirs of Feliciano Yambao, one of Hermogenes’ sons, prohibited them from entering. This led the heirs of Hermogenes to file a complaint for partition, seeking to declare their co-ownership rights and nullify any conflicting titles. The heirs of Feliciano countered that Feliciano had been in possession of the land as the owner and had obtained a free patent, resulting in Original Certificate of Title (OCT) No. P-10737.

    The Regional Trial Court (RTC) initially dismissed the complaint, asserting that the heirs of Hermogenes failed to prove Macaria’s ownership and Hermogenes’ right to inherit. However, the Court of Appeals (CA) reversed this decision, emphasizing that Feliciano’s application for a free patent acknowledged Hermogenes’ prior possession since 1944. The CA thus concluded that the parties were co-owners and ordered the RTC to proceed with partition. The heirs of Feliciano then appealed to the Supreme Court, arguing that the CA erred in recognizing co-ownership and ordering partition, which they claimed was a collateral attack on the validity of OCT No. P-10737.

    The Supreme Court denied the petition, agreeing with the Court of Appeals that the property was indeed co-owned. The Court reiterated that Feliciano’s free patent application admitted that his claim to the land stemmed from Hermogenes’ long-standing possession. This acknowledgement implicitly recognized the co-ownership of the other heirs of Hermogenes. The Court emphasized that the heirs of Feliciano failed to present any evidence that Hermogenes bequeathed the property solely to Feliciano.

    Building on this principle, the Supreme Court explained the legal implications of co-ownership. Co-ownership creates a form of trust where each owner acts as a trustee for the others. Possession by one co-owner is generally not considered adverse, as all co-owners have a right to possess the property. Therefore, prescription, or the acquisition of ownership through continuous possession, does not typically apply among co-owners unless there is a clear repudiation of the co-ownership. In the absence of such repudiation, an action for partition remains imprescriptible.

    Furthermore, the Court clarified the requirements for prescription to run against a co-owner. For a co-owner’s possession to be deemed adverse, there must be unequivocal acts of repudiation, communicated clearly to the other co-owners, with convincing evidence. The issuance of a certificate of title can serve as an open repudiation, triggering a ten-year prescriptive period for demanding partition. However, this rule only applies if the plaintiff is not in possession of the property. Here, the heirs of Hermogenes remained in possession, so the prescriptive period did not begin to run when OCT No. P-10737 was issued to Feliciano in 1989. It was only in 2005, when the heirs of Feliciano prohibited the heirs of Hermogenes from entering the property, that the right to demand partition could potentially prescribe.

    The Court also addressed the argument that the action for partition constituted a collateral attack on OCT No. P-10737. A collateral attack occurs when the validity of a certificate of title is challenged in a proceeding other than a direct action for that purpose. Here, the Supreme Court clarified that the heirs of Hermogenes were not attacking Feliciano’s title directly. Instead, they were asserting their co-ownership rights and seeking the conveyance of their shares. Their claim was based on the premise that they were co-owners, entitling them to partition and the transfer of their respective shares.

    The Court then invoked the principle of implied trust. The Court cited the case of Vda. de Figuracion, et al. v. Figuracion-Gerilla, 703 Phil. 455, 472 (2013), where the Court held:

    when Feliciano registered the subject property in his name, to the exclusion of the other heirs of Hermogenes, an implied trust was created by force of law and he was considered a trustee of the undivided shares of the other heirs of Hermogenes in the property. As trustees, the heirs of Feliciano cannot be permitted to repudiate the trust by relying on the registration.

    Therefore, Feliciano, by registering the property in his name alone, became a trustee for the other heirs of Hermogenes. As a trustee, he could not repudiate the trust by relying solely on the registration. The Court further stated, quoting the case of Ringor v. Ringor, 480 Phil. 141, 161 (2004), that “[a] trustee who obtains a Torrens title over a property held in trust for him by another cannot repudiate the trust by relying on the registration.”

    FAQs

    What was the key issue in this case? The key issue was whether the heirs of Hermogenes could seek partition of a property registered under the name of Feliciano Yambao, another heir, and whether such action constituted a collateral attack on the Torrens title.
    What is co-ownership? Co-ownership is a form of ownership where two or more persons have undivided interests in a property, each with the right to possess and use the entire property, subject to the rights of the other co-owners. Each co-owner is a trustee for each other.
    What is a free patent? A free patent is a government grant of public land to a qualified applicant who has occupied and cultivated the land for a specified period, allowing them to obtain a title.
    What is the significance of a Torrens title? A Torrens title is a certificate of ownership issued under the Torrens system of land registration, which is generally considered indefeasible and conclusive, providing strong evidence of ownership.
    What does ‘imprescriptible’ mean in the context of partition? ‘Imprescriptible’ means that the right to demand partition among co-owners does not expire or is not lost due to the passage of time, unless there has been a clear repudiation of the co-ownership.
    What constitutes a repudiation of co-ownership? Repudiation of co-ownership involves clear and unequivocal acts by one co-owner that demonstrate an intention to exclude the other co-owners from their rights, such as claiming sole ownership and denying access to the property.
    What is an implied trust? An implied trust is created by operation of law, often to prevent unjust enrichment, where one party holds property for the benefit of another without an express agreement.
    What is a collateral attack on a title? A collateral attack on a title is an attempt to challenge the validity of a land title in a proceeding that is not specifically designed for that purpose, such as a partition case.
    When does prescription run against co-owners? Prescription runs against co-owners when there are clear acts of repudiation known to the other co-owners, coupled with open, continuous, and exclusive possession by one co-owner for the period required by law.

    The Supreme Court’s decision reinforces the principle that obtaining a Torrens title does not automatically extinguish existing co-ownership rights. It underscores the importance of recognizing implied trusts and protecting the interests of all heirs in inherited properties. This ruling prevents unjust enrichment and ensures fairness in property disputes among family members.

    For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

    Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
    Source: Heirs of Feliciano Yambao v. Heirs of Hermogenes Yambao, G.R. No. 194260, April 13, 2016

  • Jurisdictional Boundaries: When the SEC Oversteps its Authority

    In Imperial vs. Armes, the Supreme Court clarified the jurisdictional boundaries between the Securities and Exchange Commission (SEC) and regional trial courts. The Court held that the SEC overstepped its authority when it ruled on the validity of a sale and the cancellation of a Torrens title, matters that fall under the jurisdiction of regular courts. This decision reinforces the principle that administrative bodies like the SEC must operate within the specific powers granted to them by law, ensuring that specialized expertise is applied appropriately without encroaching on the general jurisdiction of the courts.

    Navigating Overlaps: Can the SEC Decide on Land Ownership?

    The consolidated cases revolve around a Memorandum of Agreement (MOA) between Julian Napal and Rene Imperial to form NIDSLAND Resources and Development Corporation. Napal was to contribute land, including a specific lot (the Subject Property), while Imperial was to settle Napal’s debts and provide capital. When Napal sold the Subject Property to Alfonso Cruz, Jr. instead of conveying it to NIDSLAND, Imperial filed a derivative suit with the SEC. The SEC ruled the sale to Cruz void, ordering the transfer of the Subject Property to NIDSLAND. Cruz, however, challenged this decision, arguing the SEC lacked jurisdiction over matters of land ownership, especially since he was not a party to the original corporate agreement. This legal battle highlights the critical question of whether the SEC can adjudicate on property rights when such rights are intertwined with corporate disputes.

    The heart of the matter lies in the nature of a void judgment. According to established jurisprudence, a void judgment is legally nonexistent and holds no binding effect, as reiterated in Cañero v. University of the Philippines, where the Court stated that a void judgment “is not entitled to the respect accorded to a valid judgment, but may be entirely disregarded or declared inoperative by any tribunal in which effect is sought to be given to it.” Such a judgment, often resulting from a lack of jurisdiction or grave abuse of discretion, may be challenged directly or collaterally. In this case, Cruz sought to nullify the SEC Decision, which he argued was issued without jurisdiction over his person and property rights.

    The Supreme Court scrutinized whether Cruz pursued the correct legal remedy. Cruz’s action, initially filed as a “Petition” before the RTC, sought the nullification of the SEC Decision. While the lower courts treated it as a special civil action for certiorari, the Supreme Court clarified that it was, in essence, an action for the annulment of judgment based on lack of jurisdiction. The distinction is crucial because it determines the appropriate forum and procedural rules. However, the Court noted that Rule 47, which governs annulment of judgments, applies specifically to judgments of regional trial courts, not quasi-judicial bodies like the SEC.

    This brings to the forefront the complex issue of jurisdiction over the annulment of judgments from quasi-judicial bodies. Prior to Batas Pambansa Bilang 129 (BP 129), regional trial courts could annul judgments of quasi-judicial bodies of equal or inferior rank. However, BP 129 vested the Court of Appeals (CA) with jurisdiction over annulment of judgments of regional trial courts, remaining silent on quasi-judicial bodies. Subsequent jurisprudence, including Cole v. Court of Appeals and Galang v. Court of Appeals, affirmed that the CA lacks jurisdiction to annul judgments of quasi-judicial bodies under Rule 47.

    The landmark case of Springfield Development Corporation, Inc. v. Presiding Judge clarified that neither regional trial courts nor the CA possess jurisdiction to annul judgments of quasi-judicial bodies. The Supreme Court, in Macalalag v. Ombudsman, further emphasized that an action for annulment of judgment is a statutory right, requiring an express legal grant. Therefore, to determine whether this remedy is available, the laws and rules specific to the quasi-judicial body in question must be examined.

    Applying these principles, the Supreme Court determined that no law existed at the time of the case that allowed the filing of a petition for annulment of judgment before the regional trial courts or the CA to set aside a void judgment of the SEC based on lack of jurisdiction. As such, Cruz’s RTC Petition was deemed an improper remedy. However, this did not end the inquiry. The Court proceeded to examine whether the SEC acted with grave abuse of discretion, exceeding its jurisdiction in nullifying the sale and ordering the transfer of the Subject Property.

    In 1976, Presidential Decree No. 902-A (PD 902-A) granted the SEC quasi-judicial power over intra-corporate disputes. While this jurisdiction has since been transferred to regional trial courts designated as commercial courts, the SEC held such authority during the relevant period. The Supreme Court reiterated that the SEC’s jurisdiction is delimited to matters intrinsically connected with the regulation and internal affairs of corporations, partnerships, and associations. The determination hinges on two key tests: the relationship test, which examines the relationships between the parties, and the controversy test, which assesses whether the dispute is intrinsically linked to corporate regulation.

    The Court noted that applying these tests helps delineate jurisdiction between the SEC and ordinary courts. Where the controversy involves purely civil matters or requires the application of general laws rather than specialized corporate expertise, the case falls under the jurisdiction of ordinary courts. In the present case, the Supreme Court found that the SEC lacked jurisdiction to order the cancellation of the sale between Napal and Cruz, as well as to cancel Cruz’s TCT and order its transfer to NIDSLAND. These matters involved the application of laws on sales and land titles, falling outside the SEC’s specialized competence.

    Specifically, the SEC’s decision to annul the sale to Cruz and cancel his TCT implicated the application of laws regarding the validity of sales and the indefeasibility of Torrens titles. These were civil law concepts beyond the SEC’s purview, thus the SEC’s actions constituted a grave abuse of discretion. As defined in Air Transportation Office v. Court of Appeals, grave abuse of discretion occurs when an act is contrary to the Constitution, the law, or jurisprudence, or when executed whimsically, capriciously, or arbitrarily.

    The Court underscored that a judgment tainted by grave abuse of discretion is wholly void. Such a judgment creates no rights, imposes no duties, and has no legal effect. Relying on the principle articulated in Banco Español-Filipino v. Palanca, the Court reiterated that a void judgment can be treated as an outlaw and slain at sight. However, despite the SEC Decision being void and its derivative acts having no force and effect, the Court could not directly nullify the certificates of title issued to NIDSLAND in these proceedings due to the principle of indefeasibility of a Torrens title.

    The Torrens system ensures that a certificate of title is conclusive proof of ownership, protecting registered landowners against challenges to their title. As the Supreme Court explained in Heirs of Spouses Benito Gavino and Juana Euste v. Court of Appeals, cancelling a void certificate of title outside a proceeding instituted for that purpose would undermine public confidence in the Torrens system. Therefore, the Court emphasized that the nullity of the certificates of title should be threshed out in a separate petition for cancellation of title brought before the proper court. The Supreme Court specified that this decision serves as res judicata, definitively settling that the certificates of title issued to NIDSLAND arose out of a void judgment and should have no force and effect.

    FAQs

    What was the key issue in this case? The central issue was whether the SEC had the jurisdiction to declare a sale void and order the transfer of property, especially when the rights of a third party (Cruz) were involved. The Supreme Court ultimately ruled that the SEC overstepped its authority.
    What did the SEC decide? The SEC declared the Deed of Absolute Sale between Napal and Cruz void and ordered Napal to execute a deed of conveyance in favor of NIDSLAND. The SEC also mandated Napal to deliver the possession of the Subject Property to NIDSLAND.
    Why did the Supreme Court reverse the SEC’s decision? The Supreme Court reversed the SEC’s decision because it found that the SEC did not have jurisdiction to rule on the validity of the sale and the cancellation of the TCT, as these matters fall under the purview of regular courts. The SEC acted with grave abuse of discretion, exceeding its authority.
    What is grave abuse of discretion? Grave abuse of discretion refers to a situation where a court or tribunal exercises its judgment in a capricious, whimsical, or arbitrary manner, amounting to a lack or excess of jurisdiction. It signifies a blatant disregard of established law and jurisprudence.
    What is a void judgment? A void judgment is one rendered by a court or tribunal lacking jurisdiction over the subject matter or the parties involved. It has no legal effect and can be challenged directly or collaterally, as it creates no rights and imposes no duties.
    What is the Torrens system? The Torrens system is a land registration system where a certificate of title serves as conclusive evidence of ownership. It provides security and stability to land ownership, ensuring that registered owners are protected from adverse claims.
    Can a Torrens title be challenged? Yes, but generally only through a direct action specifically aimed at challenging the validity of the title. Collateral attacks on Torrens titles are generally prohibited to maintain the integrity of the land registration system.
    What is ‘res judicata’? Res judicata is a legal principle that prevents the same parties from relitigating issues that have already been decided by a competent court. It promotes finality and stability in judicial decisions.

    In conclusion, the Supreme Court’s decision in Imperial vs. Armes serves as a critical reminder of the importance of respecting jurisdictional boundaries. While administrative bodies like the SEC play a vital role in specialized areas of law, they must operate within the confines of their statutory authority. This case underscores the principle that matters involving general questions of law and property rights are best adjudicated by the courts, ensuring a balanced and fair application of justice.

    For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

    Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
    Source: Imperial vs. Armes, G.R. No. 178842 and 195509, January 30, 2017

  • Forged Deeds and Ejectment: Protecting Landowners from Fraudulent Sales

    In a landmark decision, the Supreme Court has reinforced the principle that a forged deed cannot serve as the basis for an unlawful detainer action. This ruling protects property owners from being unjustly evicted based on fraudulent documents. It emphasizes that courts must consider the validity of the deed when determining possession rights, ensuring that individuals are not dispossessed of their property due to forgery.

    When a Signature Sparks a Battle: Can a Forged Deed Justify Eviction?

    The case of Dizon v. Beltran revolves around a disputed property in Davao City. Eddie Dizon, a seafarer, and his wife Verona owned a house and lot. After Verona’s death, Yolanda Vida P. Beltran presented a Deed of Absolute Sale, claiming Verona had sold her the property. Eddie, however, alleged that the deed was falsified, with his and Verona’s signatures forged. Beltran then filed an action for unlawful detainer to evict Eddie and his family from the property, triggering a legal battle that reached the Supreme Court.

    At the heart of the dispute was the question of whether Beltran had a valid claim to the property based on the allegedly forged deed. The Municipal Trial Court in Cities (MTCC) initially ruled in favor of Beltran, ordering the Dizons to vacate the property. However, the Regional Trial Court (RTC) reversed this decision, finding that the signatures on the deed appeared to be falsified. The Court of Appeals (CA) then sided with Beltran, reinstating the MTCC’s decision. Ultimately, the Supreme Court weighed in, focusing on the validity of the deed and its impact on the right to possess the property.

    The Supreme Court’s analysis hinged on the principle that a forged deed is void and cannot transfer ownership. The Court cited Consolacion D. Romero and Rosario S.D. Domingo v. Engracia D. Singson, stating:

    When the deed of sale in favor of respondent was purportedly executed by the parties thereto and notarized on June 6, 2006, it is perfectly obvious that the signatures of the vendors therein, Macario and Felicidad, were forged. They could not have signed the same, because both were by then, long deceased… This makes the June 6, 2006 deed of sale null and void; being so, it is ‘equivalent to nothing; it produces no civil effect; and it does not create, modify or extinguish a juridical relation.’

    Building on this principle, the Court emphasized that if the deed was indeed forged, Beltran could not claim ownership of the property and, therefore, had no basis for an unlawful detainer action. The Court also addressed the issue of whether the RTC could consider the issue of ownership in an unlawful detainer case. While generally, unlawful detainer cases focus solely on possession, the Court acknowledged that ownership could be provisionally determined to resolve the issue of possession.

    The Court also considered the irregularity of the Deed’s notarization. The Dizons claimed that Eddie was abroad and Verona was unconscious when the deed was supposedly executed. These circumstances, according to the Court, reduced the deed to a private instrument, stripping it of the presumption of regularity. The Court referred to Adelaida Meneses (deceased) v. Venturozo:

    A defective notarization will strip the document of its public character and reduce it to a private instrument. Consequently, when there is a defect in the notarization of a document, the clear and convincing evidentiary standard normally attached to a duly-notarized document is dispensed with, and the measure to test the validity of such document is preponderance of evidence.

    Given the circumstances and the pending criminal case against Beltran for falsification, the Court concluded that there was sufficient evidence to suggest that the deed was indeed forged. The ruling underscores that a Torrens title, while generally indefeasible, does not shield fraudulent transactions. The Court also addressed the issue of the supersedeas bond, which the Dizons had filed late. While the general rule is that failure to file the bond on time results in the immediate execution of the judgment, the Court recognized exceptions, such as when supervening events make the execution inequitable.

    In this case, the Court found that the allegations of forgery and the pending criminal case justified the non-immediate execution of the MTCC judgment. The Supreme Court, therefore, sided with the Dizons, setting aside the CA’s decision and reinstating the RTC’s dismissal of the unlawful detainer case. This decision serves as a reminder that the courts will not allow fraudulent documents to be used as a basis for evicting individuals from their homes. The decision offers several practical implications, protecting landowners from being dispossessed of their properties based on questionable documents. It reinforces the importance of verifying the authenticity of documents, especially in real estate transactions.

    The Court’s ruling also highlights the importance of due process and the right to a fair hearing, ensuring that individuals are not unjustly evicted without a proper determination of the validity of the underlying documents. The Supreme Court decision effectively prevents the dispossession of property based on potentially fraudulent documents. It underscores that while registration provides strong evidence of ownership, it cannot be used to shield fraudulent transactions. This case reinforces the judiciary’s role in protecting property rights and ensuring that individuals are not unjustly deprived of their homes.

    FAQs

    What was the key issue in this case? The key issue was whether a forged deed could be used as a valid basis for an unlawful detainer action to evict the Dizons from their property.
    What did the MTCC initially decide? The MTCC initially ruled in favor of Yolanda Vida P. Beltran, ordering the Dizons to turn over possession of the property and pay monthly rent.
    How did the RTC rule on appeal? The RTC reversed the MTCC’s decision, dismissing the unlawful detainer complaint after finding that the signatures on the deed appeared to be falsified.
    What was the Court of Appeals’ decision? The Court of Appeals sided with Beltran, reinstating the MTCC’s decision and ordering the RTC to issue a writ of execution.
    What was the Supreme Court’s final ruling? The Supreme Court sided with the Dizons, setting aside the CA’s decision and reinstating the RTC’s dismissal of the unlawful detainer case, effectively preventing their eviction.
    What is a supersedeas bond? A supersedeas bond is a bond filed by a defendant in an ejectment case to stay the immediate execution of a judgment while the case is on appeal, ensuring payment of rents and damages.
    What happens if the supersedeas bond is filed late? Generally, if the supersedeas bond is filed late, the judgment can be immediately executed; however, exceptions exist when supervening events make the execution inequitable.
    What is the significance of a notarized document? A notarized document carries a presumption of regularity and due execution; however, if the notarization is defective, this presumption is lost, and the document is treated as a private instrument.
    Can a Torrens title protect against fraud? While a Torrens title provides strong evidence of ownership, it does not shield fraudulent transactions, and courts can look beyond the title to determine the validity of the underlying documents.

    The Supreme Court’s decision in Dizon v. Beltran reaffirms the fundamental principle that a forged deed cannot serve as a valid basis for an unlawful detainer action. It safeguards the rights of property owners and ensures that individuals are not unjustly evicted based on fraudulent documents, reinforcing the judiciary’s role in protecting property rights and upholding due process.

    For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

    Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
    Source: EDDIE E. DIZON AND BRYAN R. DIZON, VS. YOLANDA VIDA P. BELTRAN, G.R. No. 221071, January 18, 2017

  • Piercing the Corporate Veil: Protecting Corporate Identity in Estate Proceedings

    The Supreme Court’s decision in Mayor v. Tiu clarifies that probate courts cannot disregard the separate legal identity of a corporation to include its assets in a decedent’s estate, especially when the corporation is not a party to the probate proceedings. The ruling emphasizes that the doctrine of piercing the corporate veil is a remedy to determine liability, not to expand a court’s jurisdiction or disregard due process. This means that unless there is clear evidence of fraud or wrongdoing, the assets of a corporation cannot be automatically considered part of an individual shareholder’s estate.

    Rosario’s Will: Can a Probate Court Pierce Through Primrose Development Corporation?

    This case revolves around the estate of Rosario Guy-Juco Villasin Casilan, who upon her death, left a holographic will naming her sister, Remedios Tiu, and niece, Manuela Azucena Mayor, as executors. Following Rosario’s death, a petition for the probate of her will was filed, which initiated a legal battle involving the inclusion of properties owned by Primrose Development Corporation in Rosario’s estate. Damiana Charito Marty, claiming to be Rosario’s adopted daughter, contested the will and sought to include Primrose’s assets in the estate, arguing that the corporate veil should be pierced due to Rosario’s control over the corporation. Edwin Tiu, Remedios’ son, also filed an opposition. The central legal question is whether a probate court can disregard the separate legal existence of a corporation and include its assets in the estate of a deceased shareholder, especially when the corporation itself is not a party to the probate proceedings.

    The Regional Trial Court (RTC) initially sided with Marty, appointing a special administrator over the estate and ordering the lessees of Primrose to deposit rental income directly to the court. The RTC applied the doctrine of piercing the corporate veil, reasoning that Rosario’s estate primarily consisted of her interests in Primrose. However, the Court of Appeals (CA) reversed this decision, emphasizing that Primrose had a distinct legal personality and that the probate court lacked jurisdiction to adjudicate ownership of corporate assets. The CA underscored that properties registered under the Torrens system in Primrose’s name should be respected until nullified in a separate, appropriate action. Subsequently, the RTC partially revoked its earlier order, but still directed the petitioners to render an accounting of properties and assets registered under Primrose, leading to further legal challenges.

    Building on this principle, the Supreme Court (SC) affirmed the CA’s decision, reinforcing the principle that a corporation has a separate legal personality from its stockholders and from other corporations to which it may be connected. According to the SC, the doctrine of piercing the corporate veil is intended to prevent fraud or illegal schemes, not to automatically merge the assets of a corporation with those of its shareholders. In this case, there was no clear and convincing evidence presented to justify disregarding Primrose’s separate existence. Moreover, the probate court’s actions infringed upon Primrose’s right to due process, as the corporation was not impleaded in the probate proceedings. The Court stated:

    Piercing the veil of corporate entity applies to determination of liability not of jurisdiction; it is basically applied only to determine established liability. It is not available to confer on the court a jurisdiction it has not acquired, in the first place, over a party not impleaded in a case.

    The SC emphasized the limited jurisdiction of probate courts, stating that they cannot adjudicate or determine title to properties claimed by third parties unless those parties consent or their interests are not prejudiced. The Court cited Valera vs. Inserto to clarify this point:

    …settled is the rule that a Court of First Instance (now Regional Trial Court), acting as a probate court, exercises but limited jurisdiction, and thus has no power to take cognizance of and determine the issue of title to property claimed by a third person adversely to the decedent, unless the claimant and all the other parties having legal interest in the property consent, expressly or impliedly, to the submission of the question to the probate court for adjudgment, or the interests of third persons are not thereby prejudiced…

    The High Court also emphasized the significance of the Torrens system of land registration, under which Primrose’s properties were registered. This system provides a high degree of protection to registered owners, and a Torrens title cannot be collaterally attacked. The Court citing Cuizon vs. Ramolete, noted that the probate court should have excluded the property in question from the inventory of the estate because it was registered under the Torrens system in the name of third parties, and the court had no authority to deprive such third persons of their possession and ownership of the property.

    The Court outlined several key points supporting its decision. First, the estate of a deceased person is a juridical person, separate from the decedent and any corporation. Second, the doctrine of piercing the corporate veil was not applicable here because there was no evidence of fraud or wrongdoing that would justify disregarding Primrose’s separate legal existence. Third, the probate court exceeded its jurisdiction by attempting to determine title to properties registered in Primrose’s name without the corporation’s involvement. Fourth, the probate court did not acquire jurisdiction over Primrose and its properties because the corporation was not impleaded in the probate proceedings. As such, the Court permanently enjoined the RTC from enforcing its orders insofar as they concerned the corporate properties of Primrose, reaffirming the importance of respecting corporate identity and due process in probate proceedings.

    FAQs

    What was the key issue in this case? The key issue was whether a probate court could disregard the separate legal identity of a corporation (Primrose Development Corporation) and include its assets in the estate of a deceased shareholder (Rosario Guy-Juco Villasin Casilan). The central question was whether the doctrine of piercing the corporate veil could be applied in this context.
    What is the doctrine of piercing the corporate veil? The doctrine of piercing the corporate veil allows a court to disregard the separate legal personality of a corporation and hold its owners or shareholders liable for its actions. It is typically applied to prevent fraud or injustice when the corporate form is used as a shield.
    Why did the Supreme Court rule against piercing the corporate veil in this case? The Court found no compelling evidence of fraud or wrongdoing that would justify disregarding Primrose’s separate legal existence. It also emphasized that the probate court did not have jurisdiction over Primrose, as the corporation was not a party to the probate proceedings.
    What is the significance of the Torrens title in this case? The Torrens title, which registered Primrose’s properties, provides a high degree of protection to registered owners. It cannot be collaterally attacked and can only be altered, modified, or cancelled in a direct proceeding in accordance with law.
    What is the role of a probate court in determining property ownership? A probate court has limited jurisdiction and cannot adjudicate or determine title to properties claimed by third parties unless those parties consent or their interests are not prejudiced. It can only determine whether properties should be included in the estate’s inventory.
    What was the effect of the Supreme Court’s ruling on the probate court’s orders? The Supreme Court permanently enjoined the RTC from enforcing its orders insofar as they concerned the corporate properties of Primrose Development Corporation. This meant that the RTC could not include Primrose’s assets in the estate of Rosario Guy-Juco Villasin Casilan.
    Can a corporation’s assets be automatically included in a shareholder’s estate upon death? No, a corporation has a separate legal personality from its shareholders. Its assets cannot be automatically included in a shareholder’s estate unless there is clear evidence of fraud or wrongdoing that justifies piercing the corporate veil.
    What is the main takeaway from this case? The main takeaway is that courts must respect the separate legal identity of corporations and cannot disregard it simply to include corporate assets in a shareholder’s estate. The doctrine of piercing the corporate veil is a remedy for specific situations and requires strong evidence.

    The Mayor v. Tiu decision reinforces the importance of respecting corporate identity and due process in probate proceedings. It underscores the principle that the doctrine of piercing the corporate veil should be applied judiciously and only in cases where there is clear evidence of fraud or wrongdoing. It serves as a reminder that probate courts must respect the separate legal existence of corporations and cannot automatically include their assets in a shareholder’s estate.

    For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

    Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
    Source: Mayor v. Tiu, G.R. No. 203770, November 23, 2016

  • Mortgage in Bad Faith: Protecting Real Property Owners from Impostors

    The Supreme Court ruled that a mortgagee is not considered in good faith, and thus not protected by law, when dealing with an impostor who fraudulently mortgages a property without valid title. This decision reinforces the principle that individuals must exercise due diligence when entering into real estate transactions, ensuring the protection of rightful property owners from deceitful schemes. It underscores the importance of verifying the identity and legitimacy of parties involved in mortgage agreements.

    Deed Deception: Can a Forged Mortgage Cloud a Real Title?

    This case revolves around a property dispute where Bernardo Dimailig, the registered owner of a parcel of land, found his property mortgaged without his consent. His brother, Jovannie, entrusted the title to a broker, Editha Sanggalang, for a potential sale. Instead, Editha arranged a mortgage with Evelyn Ruiz, using an impostor posing as Bernardo. The central legal question is whether Evelyn, as the mortgagee, can claim protection as a ‘mortgagee in good faith,’ despite the fraudulent nature of the transaction and the fact that the mortgagor was not the real owner.

    The factual backdrop involves Bernardo entrusting his property title to his brother Jovannie for a potential sale. Jovannie then gave the title to Editha, a broker. Unexpectedly, a Deed of Real Estate Mortgage (REM) was executed in January 1998, without Bernardo’s knowledge. Crucially, the person who signed the REM as the mortgagor was an impostor pretending to be Bernardo. Evelyn argued she acted in good faith, relying on Jovannie’s representations and the title’s apparent validity. However, Bernardo contested the mortgage’s validity, asserting that his signature on the REM was forged, and he was abroad when it was supposedly signed.

    The Regional Trial Court (RTC) initially sided with Evelyn, stating she was a mortgagee in good faith, unaware of the impostor. The RTC emphasized that Evelyn had verified the title and found no liens or encumbrances. The Court of Appeals (CA), however, reversed this decision, declaring the REM void. The CA reasoned that the protection of an innocent purchaser for value applies only when the deed is executed by the registered owner, not through a forged deed. The CA highlighted Evelyn’s failure to verify the real identity of the person claiming to be Bernardo.

    The Supreme Court, in its analysis, emphasized the principle that a valid mortgage requires the mortgagor to have a valid title or ownership of the property. While there’s an exception for mortgagees acting in good faith, they must demonstrate that they disregarded no suspicious circumstances regarding the mortgagor’s title. The Court clarified that the doctrine of mortgagee in good faith applies when the mortgagor has already obtained a Torrens title in their name. In this case, the title remained in Bernardo’s name, and the impostor never held the title.

    The burden of proving good faith rests on the mortgagee. As the Court noted, a mortgagee cannot ignore red flags and then claim good faith. The Supreme Court found that Evelyn failed to meet this burden. First, the Deed of REM was a forged instrument. Bernardo was abroad and could not have signed it. This was further supported by the fact that the parties stipulated during pre-trial that it was not the real Bernardo who signed as mortgagor in the Deed of REM. Therefore, the forged Deed of REM is a nullity and conveys no title.

    Building on this principle, the Supreme Court emphasized that Evelyn could not claim the protection afforded to a mortgagee in good faith because the title to the property was never transferred to the impostor. As the Court stated:

    In other words, in order for a mortgagee to invoke the doctrine of mortgagee in good faith, the impostor must have succeeded in obtaining a Torrens title in his name and thereafter in mortgaging the property. Where the mortgagor is an impostor who only pretended to be the registered owner, and acting on such pretense, mortgaged the property to another, the mortgagor evidently did not succeed in having the property titled in his or her name, and the mortgagee cannot rely on such pretense as what appears on the title is not the impostor’s name but that of the registered owner.

    Even assuming the impostor had titled the property in his name, Evelyn still wouldn’t be considered a mortgagee in good faith. This is because she failed to take necessary steps to verify the mortgagor’s identity and title. The Court found several lapses in Evelyn’s conduct. She failed to ask for identification from the impostor, relying solely on a community tax certificate and a picture. The “Bernardo” in front of her did not participate in the negotiations leading up to the execution of the deed. Lastly, Evelyn also failed to verify the occupant or neighbors on the property she intended to mortgage.

    The Supreme Court, therefore, denied Evelyn’s petition, affirming the CA’s decision. The Court emphasized the importance of due diligence in mortgage transactions and that a forged instrument conveys no title. Because Evelyn failed to exercise the required diligence and the transaction involved an impostor and a forged deed, she could not claim the protection of a mortgagee in good faith.

    FAQs

    What was the key issue in this case? The central issue was whether Evelyn Ruiz could be considered a mortgagee in good faith when she entered into a mortgage agreement with an impostor who presented himself as the property owner, Bernardo Dimailig. This hinged on whether she exercised due diligence in verifying the identity of the mortgagor and the validity of the title.
    What does ‘mortgagee in good faith’ mean? A ‘mortgagee in good faith’ refers to someone who, when granting a loan secured by a property, acts without any knowledge or suspicion that the mortgagor’s title is defective or that the transaction involves fraud. They are typically protected by law if the mortgagor’s title later turns out to be invalid.
    Why was Evelyn Ruiz not considered a mortgagee in good faith? Evelyn Ruiz was not considered a mortgagee in good faith because she failed to take reasonable steps to verify the identity of the person claiming to be Bernardo Dimailig and did not adequately investigate the circumstances surrounding the mortgage transaction. The Court found her reliance on the impostor’s representations without further verification to be negligent.
    What steps should mortgagees take to ensure they are acting in good faith? Mortgagees should verify the identity of the mortgagor by requesting and scrutinizing valid identification documents, conduct thorough due diligence to confirm the mortgagor’s ownership and title to the property, and investigate any red flags or inconsistencies in the transaction. They should also inquire about the property’s occupants and their relationship to the mortgagor.
    What is the effect of a forged Deed of Real Estate Mortgage? A forged Deed of Real Estate Mortgage is considered a nullity, meaning it has no legal effect from the beginning. It cannot transfer any rights or interests in the property, and the rightful owner retains full ownership and control.
    Can a property owner lose their title due to a forged mortgage? Generally, a property owner cannot lose their title due to a forged mortgage, especially if they were not involved in or aware of the fraudulent transaction. The law protects the rights of the registered owner in such cases.
    What recourse does the mortgagee have if the mortgage is declared void? If the mortgage is declared void due to fraud or forgery, the mortgagee may have recourse against the party who perpetrated the fraud, seeking damages for the losses incurred. However, they generally cannot recover the property itself from the rightful owner.
    What was the Court of Appeal’s ruling on the Deed of Real Estate Mortgage? The Court of Appeals reversed the Regional Trial Court’s decision, declaring the Deed of Real Estate Mortgage null and void. They ordered Evelyn V. Ruiz to return the owner’s duplicate copy of the title to Bernardo F. Dimailig, the rightful owner.

    This case serves as a critical reminder of the importance of due diligence and vigilance in real estate transactions. It underscores the need for mortgagees to thoroughly verify the identity and legitimacy of mortgagors to protect themselves from fraud and ensure the security of their investments. The ruling reinforces the principle that the rights of the registered property owner are paramount when faced with fraudulent claims.

    For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

    Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
    Source: Evelyn V. Ruiz v. Bernardo F. Dimailig, G.R. No. 204280, November 09, 2016

  • Jurisdiction Over Real Property Disputes: The Importance of Assessed Value

    The Supreme Court has clarified that a court’s jurisdiction in real property disputes hinges on the property’s assessed value as stated in the complaint. If the complaint fails to specify this value, the court lacks the necessary basis to determine its jurisdiction, potentially leading to the dismissal of the case. This ruling emphasizes the critical importance of including all essential information in legal filings to ensure cases are heard in the correct venue.

    When Manila’s Residents Clashed with Patricia Inc: A Question of Property Boundaries

    This case arose from a dispute between Guillermo Salvador, Remedios Castro, and other residents of Manila, who filed an action for injunction and quieting of title against Patricia, Inc. The residents sought to prevent Patricia, Inc., from evicting them from the properties they occupied. Central to the dispute was the determination of who owned the land: Patricia, Inc., or the City of Manila. The residents claimed their right to the land, citing long-term occupancy and improvements they had made. The City of Manila and Ciriaco C. Mijares intervened, further complicating the matter. The heart of the legal question was whether the Regional Trial Court (RTC) had the jurisdiction to resolve the dispute, especially considering the lack of clarity regarding the property’s assessed value in the complaint.

    The petitioners argued that the issue of the boundary was openly raised and litigated in the RTC, effectively amending the complaint to conform to the evidence presented, as stipulated in Section 5, Rule 10 of the Rules of Court. They asserted that they had a sufficient interest to bring the suit due to the improvements they had built on the property. The City of Manila supported the petitioners, emphasizing the application of Section 5, Rule 10 of the Rules of Court. Conversely, Patricia, Inc., contended that the boundary dispute was not appropriate for an action of quieting title under Rule 63 of the Rules of Court. The company argued that Section 5, Rule 10 did not authorize the RTC to resolve the boundary dispute.

    The Supreme Court, in its ruling, addressed the fundamental issue of jurisdiction. It emphasized that the power of a court to hear and decide a case, its jurisdiction, is determined by law. This jurisdiction cannot be presumed, implied, or conferred by the agreement of the parties. Rather, it must clearly appear from the law itself. The Court highlighted the three essential elements of jurisdiction: the court must have cognizance of the class of cases to which the one to be adjudged belongs, the proper parties must be present, and the point decided must be within the issue. The nature of the case, as made by the complaint, and the relief sought determine the jurisdiction of the court.

    The Court then discussed the exclusive original jurisdiction of the Regional Trial Courts (RTC) in civil cases, as outlined in Section 19 of Batas Pambansa Blg. 129, also known as the Judiciary Reorganization Act of 1980. According to this law, the RTC has jurisdiction over civil actions in which the subject of the litigation is incapable of pecuniary estimation and actions involving title to or possession of real property. However, the Court also noted the expansion of jurisdiction for first-level courts under Republic Act No. 7691, amending Section 33(3) of Batas Pambansa Blg. 129, effective April 15, 1994. This amendment grants Metropolitan Trial Courts, Municipal Trial Courts, and Municipal Circuit Trial Courts exclusive original jurisdiction over civil actions involving title to or possession of real property, provided the assessed value of the property does not exceed specified amounts.

    The Supreme Court pointed out that the petitioners’ complaint lacked any averment of the assessed value of the property. This omission left the trial court without a basis to determine which court had jurisdiction over the action for quieting of title. The Court asserted that, even though the parties did not raise the issue of jurisdiction, it could consider and resolve it motu proprio, as jurisdiction is conferred only by law. This principle is crucial because it prevents parties from manipulating the legal process by consenting to a court’s jurisdiction that does not exist.

    Another significant aspect of the case involved the joinder of the action for injunction and the action to quiet title. The Court noted that Section 5, Rule 2 of the Rules of Court disallows the joinder of special civil actions with ordinary suits. Since an action for quieting of title is a special civil action under Rule 63, it should not have been joined with the ordinary action for injunction. The RTC should have severed the causes of action and tried them separately. The refusal of the petitioners to accept the severance could have led to the dismissal of the case.

    Moreover, the Court found that the petitioners had not demonstrated that they were real parties in interest to demand either injunction or quieting of title. The action to quiet title requires that the plaintiff have a legal or equitable title to or interest in the real property. The petitioners did not claim ownership of the land itself, nor did they show a legal basis for their alleged lawful occupation. Their contention of long-term possession and good faith improvements was insufficient to establish the necessary interest. The Court cited Article 477 of the Civil Code, which requires the plaintiff to have a legal or equitable title to the property.

    The Court also addressed the argument that the area’s declaration as an Area for Priority Development (APD) under Presidential Decree No. 1967 provided sufficient interest to the petitioners. While Presidential Decree No. 1517 grants occupants of APDs the right of first refusal, this right accrues only if and when the owner decides to sell the property. The Court also stated that the petitioners’ admission of the genuineness and authenticity of Patricia, Inc.’s title negated any claim that there was a deed, instrument, encumbrance, or proceeding that was invalid and cast a cloud on their title.

    Regarding the petitioners’ cause of action for injunction, the Court referenced Philippine Economic Zone Authority v. Carantes, stating that to issue an injunction, there must be a right to be protected, and the acts against which the injunction is directed must violate that right. The petitioners failed to prove the existence of a right to be protected. The dispute concerned the boundary between Patricia, Inc., and the City of Manila, not the petitioners.

    The Court dismissed the petitioners’ invocation of Section 5, Rule 10 of the Rules of Court to raise the boundary dispute, reiterating that a boundary dispute should not be litigated in an action for quieting of title. Doing so would violate Section 48 of the Property Registration Decree, which prohibits collateral attacks on Torrens titles. A collateral attack occurs when the certificate of title is assailed as an incident in another action to obtain a different relief. The petitioners sought to modify or cancel Patricia, Inc.’s title, which constitutes a collateral attack.

    FAQs

    What was the key issue in this case? The central issue was whether the Regional Trial Court (RTC) had jurisdiction over the action for quieting of title, given that the complaint did not specify the assessed value of the property.
    Why is the assessed value of the property important? The assessed value determines which court has jurisdiction over real property disputes. Lower courts have jurisdiction if the value is below a certain threshold, while RTCs handle cases exceeding that value.
    What is an action for quieting of title? It is a legal action taken to remove any cloud or uncertainty affecting the title to real property, ensuring clear and undisputed ownership. This action is governed by Rule 63 of the Rules of Court.
    What happens if the assessed value is not stated in the complaint? The court lacks the necessary information to determine its jurisdiction, potentially leading to the dismissal of the case. The court can also raise this issue motu proprio.
    Can an action for quieting of title be combined with other actions? No, under the Rules of Court, a special civil action like quieting of title cannot be joined with an ordinary civil action like injunction. They must be pursued separately.
    Who can file an action for quieting of title? Only someone with a legal or equitable title to, or interest in, the real property that is the subject of the action. This means the plaintiff must have some ownership or right to the property.
    What is the significance of an Area for Priority Development (APD)? Being in an APD grants occupants certain rights, such as the right of first refusal to purchase the property if the owner decides to sell. However, it does not automatically confer ownership or the right to file a quieting of title action.
    What is a collateral attack on a Torrens title? It is an attempt to challenge the validity of a certificate of title in a lawsuit where the main goal is something other than altering or canceling the title itself. This is generally prohibited by the Property Registration Decree.

    In summary, the Supreme Court’s decision underscores the importance of accurately stating the assessed value of the property in complaints involving real actions. It also clarifies the rules on joinder of actions and who may bring an action for quieting of title. This case serves as a reminder to ensure strict compliance with procedural rules to avoid potential pitfalls in litigation.

    For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

    Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
    Source: Guillermo Salvador, Remedios Castro, et al. v. Patricia, Inc., G.R. No. 195834, November 9, 2016

  • Jurisdiction and Real Actions: Assessed Value Determines Court Authority in Philippine Property Disputes

    In the Philippines, determining which court has the authority to hear a property dispute hinges on the property’s assessed value as stated in the initial complaint. If the complaint fails to mention the assessed value, the court lacks the necessary information to establish its jurisdiction, potentially leading to the dismissal of the case. This ruling underscores the importance of accurately presenting jurisdictional facts at the outset of legal proceedings involving real property, ensuring that the case is filed in the correct court from the beginning. This prevents unnecessary delays and legal complications, saving time and resources for all parties involved.

    When Silence Speaks Volumes: The Case of Omitted Property Values and Jurisdictional Void

    The case of Guillermo Salvador, et al. v. Patricia, Inc. revolves around a dispute over land ownership in Manila, where the petitioners, occupants of a property, sought to prevent Patricia, Inc. from evicting them. The core legal question was whether the Regional Trial Court (RTC) had the jurisdiction to hear the case, given that the complaint did not specify the assessed value of the property in question. This omission became critical because, under Philippine law, the assessed value of the property determines which court—either the Municipal Trial Court (MTC) or the Regional Trial Court (RTC)—has the authority to preside over real actions.

    The Supreme Court (SC) emphasized that jurisdiction is conferred by law and cannot be presumed. It reiterated that for real actions, which involve the title to or possession of real property, the assessed value of the property is the determining factor for jurisdiction. The relevant provision of Batas Pambansa Blg. 129, as amended by Republic Act No. 7691, stipulates that MTCs have exclusive original jurisdiction over civil actions involving title to or possession of real property where the assessed value does not exceed P20,000, or P50,000 in Metro Manila. In the absence of any allegation regarding the property’s assessed value, the RTC lacked the basis to determine whether it had jurisdiction over the action to quiet title.

    Furthermore, the SC noted that the petitioners improperly joined an action for injunction with the action to quiet title, the former being an ordinary suit and the latter a special civil action under Rule 63 of the Rules of Court. According to Section 5, Rule 2 of the Rules of Court, such joinder is not allowed. If the RTC had jurisdiction, it should have severed the causes of action and tried them separately. Section 6, Rule 2 provides that misjoinder of causes of action is not a ground for dismissal; instead, the court may sever the misjoined cause of action.

    The Court also pointed out that the petitioners failed to demonstrate that they were real parties in interest to demand either injunction or quieting of title. To bring an action for quieting of title, the plaintiff must have a legal or equitable title to, or interest in, the real property. The petitioners did not claim ownership of the land, nor did they establish any legal basis for their alleged lawful occupation. Their claim of possession for over 30 years and the declaration of the area as an Area for Priority Development (APD) were insufficient to vest them with the necessary interest to maintain the action.

    “for an action to quiet title to prosper, two indispensable requisites must concur, namely: (1) the plaintiff or complainant has a legal or an 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 cloud on his title must be shown to be in fact invalid or inoperative despite its prima facie appearance of validity or legal efficacy.” Mananquil v. Moico, G.R. No. 180076, November 21, 2012

    The SC also addressed the petitioners’ reliance on Section 5, Rule 10 of the Rules of Court to raise the boundary dispute. The Court clarified that a boundary dispute should not be litigated in an action for quieting of title and that the action for quieting title is specifically used to remove any cloud upon, doubt, or uncertainty affecting title to real property. Allowing the boundary dispute to be litigated in the action for quieting of title would violate Section 48 of the Property Registration Decree, which prohibits collateral attacks on Torrens titles.

    Furthermore, the Supreme Court explained that even if the area was declared an area for priority development (APD) under Presidential Decree No. 1967, as amended, this did not provide sufficient interest to the petitioners. Presidential Decree No. 1517 only granted to the occupants of APDs the right of first refusal, but such grant was true only if and when the owner of the property decided to sell the property. Consequently, the right of first refusal remained contingent, and was for that reason insufficient to vest any title, legal or equitable, in the petitioners.

    In conclusion, the Supreme Court affirmed the Court of Appeals’ decision, emphasizing that jurisdiction over a real action is determined by the assessed value of the property as alleged in the complaint. The failure to include this information is a critical omission that can lead to the dismissal of the case for lack of jurisdiction. The decision serves as a reminder of the importance of adhering to procedural rules and accurately presenting jurisdictional facts in legal pleadings.

    FAQs

    What was the key issue in this case? The central issue was whether the Regional Trial Court (RTC) had jurisdiction over an action to quiet title when the complaint did not state the assessed value of the property. This omission is crucial because the assessed value determines which court (Municipal Trial Court or Regional Trial Court) has jurisdiction over real actions.
    What is a real action? A real action is a legal proceeding that involves the title to, or possession of, real property, or any interest in such property. These actions are distinct from personal actions, which involve disputes over personal rights or obligations.
    Why is the assessed value of the property important? The assessed value of the property is important because it determines which court has the authority (jurisdiction) to hear cases involving real property. Lower courts typically handle cases where the assessed value is below a certain threshold.
    What happens if the complaint doesn’t mention the assessed value? If the complaint does not state the assessed value, the court lacks the necessary information to determine whether it has jurisdiction over the case. This omission can lead to the dismissal of the case for lack of jurisdiction.
    What is an action to quiet title? An action to quiet title is a legal proceeding aimed at removing any cloud, doubt, or uncertainty affecting the title to real property. It is designed to ensure that the owner has clear and undisputed ownership of the property.
    Who can bring an action to quiet title? Only individuals or entities with a legal or equitable title to, or interest in, the real property can bring an action to quiet title. The plaintiff must demonstrate a valid claim to the property.
    Can different causes of action be joined in one complaint? While the Rules of Court allow the joinder of multiple causes of action, they specifically prohibit joining special civil actions (like quieting of title) with ordinary suits (like injunction) in the same pleading. These must be filed separately.
    What is the significance of an Area for Priority Development (APD)? The declaration of an area as an APD grants certain rights to occupants, such as the right of first refusal if the property owner decides to sell. However, this status alone does not vest legal or equitable title in the occupants.
    What is a collateral attack on a Torrens title? A collateral attack on a Torrens title occurs when the validity of the title is challenged in a legal proceeding that has a different primary objective. Philippine law prohibits collateral attacks on Torrens titles, requiring any challenge to be made in a direct proceeding.

    This case underscores the critical importance of accurately pleading jurisdictional facts, particularly the assessed value of the property, in real actions. Failure to do so can have significant consequences, including the dismissal of the case. Understanding the nuances of jurisdiction and the requirements for bringing an action to quiet title are essential for anyone involved in property disputes in the Philippines.

    For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

    Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
    Source: Guillermo Salvador, et al. v. Patricia, Inc., G.R. No. 195834, November 09, 2016

  • Good Faith in Construction: Rights and Obligations of Builders and Landowners

    In the case of Padilla v. Malicsi, the Supreme Court clarified the rights and obligations of a builder in bad faith on another’s land. The Court ruled that individuals who construct on land they mistakenly believe belongs to another, without sufficient investigation, cannot claim the benefits of a builder in good faith. This decision emphasizes the importance of verifying land ownership before construction and outlines the remedies available to landowners when faced with unauthorized building.

    Building on Misconceptions: Who Pays When Good Faith Falters?

    Spouses Padilla owned a 150-square-meter parcel of land in Cabanatuan City, covered by Transfer Certificate Title No. T-45565. In 1998, they discovered that Leopoldo Malicsi, Lito Casino, and Agrifino Guanes (Malicsi, et al.) had built houses on their property. The Padillas demanded that Malicsi, et al. vacate the premises and pay rent, but these demands were ignored. Malicsi, et al. claimed they believed the land belonged to Toribia Vda. De Mossessgeld, who had given them permission to build, with an agreement to eventually sell them the land they occupied. The Regional Trial Court (RTC) initially ruled against Malicsi, et al., finding them not to be builders in good faith, but the Court of Appeals (CA) reversed this decision, declaring them builders in good faith. This discrepancy led to the Supreme Court review.

    The central issue before the Supreme Court was whether Malicsi, et al. were builders in good faith. The determination of good faith is crucial because it dictates the rights and obligations of both the landowner and the builder. A builder in good faith is someone who, when constructing on another’s land, is unaware of any defect or flaw in their title. This contrasts with a builder in bad faith, who knows or should have known that they are building on someone else’s property without right. The Civil Code provides different remedies for these two scenarios.

    The Supreme Court, in reversing the Court of Appeals’ decision, emphasized the importance of due diligence in ascertaining land ownership. The Court referenced Article 448 of the Civil Code, which governs the rights of a landowner when a builder has constructed in good faith. This article gives the landowner the option to either appropriate the building after paying indemnity or to oblige the builder to purchase the land. However, the Court found that Malicsi, et al. could not be considered builders in good faith because they failed to exercise reasonable diligence in verifying ownership before building on the land. Their reliance on De Mossessgeld’s representation, without further inquiry, was deemed insufficient to establish good faith.

    Article 448. The owner of the land on which anything has been built, sown or planted in good faith, shall have the right to appropriate as his own the works, sowing or planting, after payment of the indemnity provided for in Articles 546 and 548, or to oblige the one who built or planted to pay the price of the land, and the one who sowed, the proper rent. However, the builder or planter cannot be obliged to buy the land if its value is considerably more than that of the building or trees. In such case, he shall pay reasonable rent, if the owner of the land does not choose to appropriate the building or trees after proper indemnity. The parties shall agree upon the terms of the lease and in case of disagreement, the court shall fix the terms thereof.

    The Court distinguished the case from previous rulings where good faith was established due to peculiar circumstances, such as close family relations where reliance on a relative’s representation of ownership was deemed reasonable. In this case, De Mossessgeld was a stranger to Malicsi, et al., and this should have prompted them to conduct a more thorough investigation into the land’s ownership. Since the land was already titled to the mother of Pablo M. Padilla, Jr. as early as 1963, a simple check with the Registry of Deeds would have revealed the true owner.

    Since Malicsi, et al. were deemed builders in bad faith, they lost the right to indemnity for the improvements they had made on the land. Article 449 of the Civil Code states that a builder in bad faith loses what is built without right to indemnity. The landowner, in this case, has the right to appropriate the improvements without any obligation to compensate the builder. Alternatively, the landowner can demand the demolition of the work or compel the builder to pay the price of the land, as outlined in Article 450 of the Civil Code. In addition to these remedies, Article 451 provides that the landowner is entitled to damages from the builder in bad faith.

    The Supreme Court pointed out that the Padillas, by seeking the reinstatement of the RTC decision ordering Malicsi, et al. to vacate the property, had effectively chosen to appropriate the improvements without paying indemnity. This decision underscores the importance of verifying land ownership before commencing any construction. It also highlights the legal consequences of failing to exercise due diligence in such matters. The rights of a landowner are significantly stronger against a builder in bad faith, allowing for the appropriation of improvements without compensation.

    FAQs

    What was the key issue in this case? The central issue was whether the respondents were builders in good faith when they constructed houses on land owned by the petitioners. The Supreme Court ultimately determined they were not, due to their failure to verify land ownership.
    What is a builder in good faith? A builder in good faith is someone who constructs on another’s land believing they have a right to do so, without knowledge of any defect in their claim. This belief must be honest and reasonable, based on sufficient inquiry.
    What is a builder in bad faith? A builder in bad faith is someone who knows or should have known that they are building on land they do not own or have a right to build on. They act without a reasonable belief in their right to construct.
    What rights does a landowner have against a builder in bad faith? The landowner can choose to appropriate the building without paying indemnity, demand demolition at the builder’s expense, or compel the builder to pay for the land. Additionally, the landowner is entitled to damages.
    What are the remedies available to a landowner when someone builds in good faith on their property? The landowner can appropriate the building by paying the builder indemnity or oblige the builder to purchase the land. If the land’s value is considerably higher, a forced lease may be created.
    Why were the respondents not considered builders in good faith in this case? The respondents failed to exercise due diligence in verifying the land’s ownership before building. Their reliance on a stranger’s claim of ownership was deemed insufficient.
    What should individuals do before building on a property? Individuals should conduct a thorough investigation of the property’s ownership by checking with the Registry of Deeds and examining relevant documents. This ensures they have a legal right to build on the land.
    What is the significance of the Torrens title in this case? The existence of a Torrens title, which serves as evidence of ownership, puts the burden on the builders to prove they acted in good faith, a burden they failed to meet. The court gives high regard to the Torrens title.

    The Padilla v. Malicsi case serves as a reminder of the importance of verifying land ownership before undertaking construction. It clarifies the distinction between builders in good faith and bad faith, and it underscores the legal remedies available to landowners in cases of unauthorized building. Understanding these principles can help prevent costly disputes and ensure that property rights are respected.

    For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

    Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
    Source: Padilla, Jr. vs. Malicsi, G.R. No. 201354, September 21, 2016

  • Torrens Title vs. Actual Possession: Upholding Ownership Rights in Unlawful Detainer Cases

    In a dispute over property possession, the Supreme Court affirmed that a Torrens title holds significant weight, granting the registered owner the right to possess the property. This ruling emphasizes that even if occupants claim rights based on other documents or alleged agreements, the registered owner’s title generally prevails in unlawful detainer cases. The decision reinforces the principle that a Torrens title serves as strong evidence of ownership and the right to possess the property, unless successfully challenged through direct legal action. This underscores the importance of registering land titles to protect property rights.

    Possession Battle: Can a Land Title Trump Claims of Prior Authorization?

    This case revolves around a complaint for unlawful detainer filed by Feliza Cruz Vda. De Ranin against Spouses Lolita and Pedro Orencia, concerning Door No. 4 of a seven-door apartment complex. Ranin claimed that the Orencias failed to pay rent and refused to vacate the property despite a formal demand. The Orencias countered that Ranin was not the true owner and that they were authorized to occupy the premises by one Lea Liza Cruz Ranin. The Municipal Trial Court (MTC) and Regional Trial Court (RTC) initially sided with the Orencias, but the Court of Appeals (CA) reversed these decisions, leading to the Supreme Court review.

    The central legal question before the Supreme Court was whether Ranin, as the holder of a Transfer Certificate of Title (TCT), had the right to physical possession of the property, even if the Orencias claimed authorization from another party. This issue touches on the fundamental principles of property law, specifically the weight given to registered titles under the Torrens system versus claims of actual possession or prior agreements. The Torrens system, designed to provide security and stability in land ownership, is put to the test when faced with conflicting claims of possession.

    The Supreme Court began by reiterating the limited scope of review under Rule 45 of the Rules of Court, which generally restricts its jurisdiction to errors of law. However, the Court acknowledged the conflicting findings of the lower courts, necessitating a review of the evidence. This underscores the Court’s power to delve into factual matters when the lower courts diverge in their interpretations. The Court then addressed the Orencias’ arguments, which primarily centered on Ranin’s alleged lack of ownership and the existence of a tax declaration in the name of Lea Liza Cruz Ranin.

    The Court emphasized the nature of unlawful detainer cases, stating:

    “Unlawful detainer is an action to recover possession of real property from one who unlawfully withholds possession after the expiration or termination of his right to hold possession under any contract, express or implied…The sole issue for resolution in an unlawful detainer case is physical or material possession of the property involved, independent of any claim of ownership by any of the parties. When the defendant, however, raises the defense of ownership in his pleadings and the question of possession cannot be resolved without deciding the issue of ownership, the issue of ownership shall be resolved only to determine the issue of possession.”

    Guided by this principle, the Court determined that Ranin’s complaint sufficiently established a case of unlawful detainer. The Court noted that the Orencias’ possession, initially lawful, became unlawful upon their failure to pay rent and comply with the demand to vacate. This highlights the critical elements of an unlawful detainer case: prior lawful possession that has become unlawful due to the expiration or termination of the right to possess. The Court underscored that the core issue was who had a better right to possession, which in turn required an examination of the ownership claims.

    The Court found that Ranin had successfully proven her ownership and right to possession through the presentation of TCT No. 514491, registered under her name. This TCT, the Court asserted, served as evidence of an indefeasible title, entitling Ranin to possession as a matter of right. Building on this principle, the Court cited established jurisprudence, stating:

    “There is no question that the holder of a Torrens title is the rightful owner of the property thereby covered and is entitled to its possession.”

    This underscores the strong presumption in favor of the registered owner under the Torrens system. The Court contrasted Ranin’s evidence with the Orencias’ bare allegations that Ranin was not the owner. The Court found that the Orencias failed to present any evidence to support their claim of a right to possess the property. Consequently, the Court concluded that their unsubstantiated arguments were insufficient to overcome Ranin’s right as the registered owner.

    The Court also addressed the lower courts’ reliance on Tax Declaration (TD) No. TY 004-13393, which was in the name of Lea Liza Cruz Ranin. The MTC and RTC had erroneously given more weight to this tax declaration than to Ranin’s Torrens title. This approach contrasts with established legal principles, where a certificate of title is generally considered a stronger evidence of ownership than a tax declaration. The Court emphasized that a tax declaration is primarily for tax purposes and does not conclusively establish ownership.

    The Court further noted that the Orencias’ attempt to challenge the validity of Ranin’s TCT and TD No. 00-TY-004-5912 amounted to a collateral attack on the Torrens title, which is impermissible in an unlawful detainer case. The Court has consistently held that a Torrens title is presumed legal and cannot be collaterally attacked, especially in a summary action for unlawful detainer. This principle aims to protect the stability and reliability of the Torrens system by preventing challenges to titles in inappropriate proceedings.

    The Court dismissed the Orencias’ other claims, including their denial of receiving the demand letter and their assertion that there was no prior conciliation proceeding before the barangay. The Court found that the certification from the Postmaster of Taytay, Rizal, proved that the Orencias had received the demand letter. Additionally, the Court pointed to the Certification to File Action, issued on December 15, 2005, as evidence of prior conciliation proceedings. These findings highlight the importance of presenting credible evidence to support factual claims in legal proceedings.

    In conclusion, the Supreme Court upheld the CA’s decision, affirming Ranin’s right to possess the property based on her Torrens title. The Court emphasized the weight given to registered titles under the Torrens system and the impermissibility of collateral attacks on such titles in unlawful detainer cases. This decision reinforces the principle that a Torrens title serves as strong evidence of ownership and the right to possess the property, unless successfully challenged through direct legal action. The case underscores the importance of registering land titles to protect property rights and provides clarity on the resolution of possession disputes when ownership is contested.

    FAQs

    What was the key issue in this case? The key issue was whether Feliza Cruz Vda. De Ranin, as the holder of a Transfer Certificate of Title (TCT), had the right to physical possession of the property, despite the claim of Spouses Orencia that they were authorized to occupy the premises by another party. This centered on the weight given to a registered title versus claims of prior authorization in an unlawful detainer case.
    What is unlawful detainer? Unlawful detainer is a legal action to recover possession of real property from someone who unlawfully withholds possession after their right to possess has expired or been terminated. The core issue is the right to physical possession, independent of ownership claims.
    What is a Torrens title? A Torrens title is a certificate of title issued under the Torrens system of land registration, which provides a conclusive record of ownership. It serves as evidence of an indefeasible title, meaning it cannot be easily defeated or challenged.
    Why is a Torrens title important in this case? The Torrens title held by Feliza Cruz Vda. De Ranin was crucial because the Supreme Court recognized it as strong evidence of her ownership and right to possess the property. The Court emphasized that the holder of a Torrens title is generally entitled to possession.
    What is a tax declaration and how does it relate to property ownership? A tax declaration is a document used for tax purposes, primarily to assess and collect real property taxes. While it lists the property owner, it is not conclusive evidence of ownership and does not outweigh a Torrens title.
    What does it mean to collaterally attack a Torrens title? A collateral attack on a Torrens title refers to an attempt to challenge the validity of the title in a legal proceeding that is not specifically designed for that purpose. The Supreme Court does not allow collateral attacks on Torrens titles, especially in unlawful detainer cases.
    What evidence did Spouses Orencia present to support their claim? Spouses Orencia primarily argued that Feliza Cruz Vda. De Ranin was not the true owner and that they had been authorized to occupy the property by Lea Liza Cruz Ranin. However, they did not provide concrete evidence to support their claim of authorization or ownership.
    What was the significance of the demand letter and conciliation proceedings? The demand letter and conciliation proceedings were important because they are prerequisites for filing an unlawful detainer case. The Supreme Court found that Feliza Cruz Vda. De Ranin had complied with these requirements, as evidenced by the Postmaster’s certification and the Certification to File Action.

    This case underscores the importance of the Torrens system in the Philippines and the protection it affords to registered landowners. It serves as a reminder that while actual possession and other claims may be relevant, a valid Torrens title generally prevails in determining the right to possess property. Understanding these principles is crucial for both landowners and occupants of property in resolving possession disputes.

    For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

    Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
    Source: Spouses Lolita Orencia and Pedro D. Orencia vs. Felisa Cruz Vda. De Ranin, G.R. No. 190143, August 10, 2016

  • Torrens Title vs. Actual Possession: Resolving Property Disputes in Unlawful Detainer Cases

    In Spouses Lolita Orencia and Pedro D. Orencia vs. Felisa Cruz Vda. De Ranin, the Supreme Court reiterated the paramount importance of a Torrens title in resolving property disputes. The Court held that the registered owner of a property under the Torrens system has the right to its possession, even if another party claims actual possession or ownership based on other documents. This ruling underscores the indefeasibility of a Torrens title and its evidentiary value in establishing ownership and the right to possess property, providing clarity and security in land ownership disputes.

    Possession Predicaments: When a Land Title Trumps a Claim of Occupancy

    This case originated from a complaint for unlawful detainer filed by Feliza Cruz Vda. De Ranin against Spouses Lolita and Pedro Orencia. Ranin sought to recover possession of Door No. 4 of an apartment complex registered under her name, arguing that the Orencias had ceased paying rent and refused to vacate the premises despite a formal demand. The Orencias countered that Ranin was not the true owner and that they had been authorized to occupy the property by another individual, Lea Liza Cruz Ranin.

    The Municipal Trial Court (MTC) and the Regional Trial Court (RTC) initially sided with the Orencias, focusing on a tax declaration in the name of Lea Liza Cruz Ranin, which suggested that she owned the apartment. However, the Court of Appeals (CA) reversed these decisions, emphasizing that Feliza Cruz Vda. De Ranin held a Transfer Certificate of Title (TCT) in her name, which established her superior right to possess the property. The Supreme Court then affirmed the CA’s decision, reinforcing the significance of a Torrens title in determining the right to possession.

    The central issue before the Supreme Court was whether Feliza Cruz Vda. De Ranin, as the registered owner under a Torrens title, had the right to physical possession of the disputed property. The Court’s ruling rested on the established principle that a Torrens title serves as evidence of an indefeasible and incontrovertible title to the property in favor of the person whose name appears therein. The titleholder is entitled to all the attributes of ownership of the property, including possession. This principle is deeply rooted in Philippine jurisprudence, ensuring stability and predictability in land ownership.

    The Supreme Court emphasized the nature of an unlawful detainer case, which is an action to recover possession of real property from one who unlawfully withholds possession after the expiration or termination of his right to hold possession under any contract, express or implied. The Court highlighted that the sole issue for resolution in an unlawful detainer case is physical or material possession of the property involved, independent of any claim of ownership by any of the parties. However, when the defendant raises the defense of ownership, the issue of ownership shall be resolved only to determine the issue of possession.

    In this case, the Orencias’ defense centered on the claim that Ranin was not the true owner of the property. They presented a tax declaration in the name of Lea Liza Cruz Ranin and argued that they had been authorized to occupy the property by her. However, the Supreme Court found that Ranin had sufficiently proven her ownership through her Torrens title. The Court noted that the Orencias failed to present any evidence to support their claim of ownership or right to possess the property, and the Supreme Court stated that:

    There is no question that the holder of a Torrens title is the rightful owner of the property thereby covered and is entitled to its possession.

    Moreover, the Court rejected the Orencias’ attempt to challenge the validity of Ranin’s Torrens title collaterally in the unlawful detainer case. The Court reiterated the rule that a Torrens title cannot be collaterally attacked, especially in a mere action for unlawful detainer. This principle protects the integrity and reliability of the Torrens system, ensuring that titles are not easily undermined by indirect challenges.

    The Court also addressed the Orencias’ procedural arguments, such as the claim that they did not receive the demand letter and that there was no prior conciliation proceeding before the barangay. The Court found that these arguments were contradicted by the evidence on record, including the certification from the Postmaster of Taytay, Rizal, and the Certification to File Action issued by the barangay. These findings further supported the Court’s conclusion that Ranin had complied with the procedural requirements for filing an unlawful detainer case.

    Building on this principle, the Court addressed the implications of having a Torrens title. The TCT of the respondent is, therefore, evidence of indefeasible title over the subject property and, as its holder, she is entitled to its possession as a matter of right. The Court stated that:

    At any rate, it is fundamental that a certificate of title serves as evidence of an indefeasible and incontrovertible title to the property in favor of the person whose name appears therein. The titleholder is entitled to all the attributes of ownership of the property, including possession. Thus, the Court must uphold the age-old rule that the person who has a Torrens title over a land is entitled to its possession.

    This ruling has significant implications for property disputes in the Philippines. It reinforces the security and reliability of the Torrens system, providing clear guidelines for resolving conflicts over land ownership and possession. The decision underscores the importance of registering property under the Torrens system to protect one’s rights and interests, as the registered owner is presumed to have the right to possess the property.

    The Court also highlighted the contrast between a tax declaration and a Torrens title, stating that the trial courts erroneously relied on the tax declaration to support their finding that the respondent is not the owner of the subject property. A Torrens title, as evidence of indefeasible ownership, carries more weight than a mere tax declaration. While tax declarations may be used to prove possession, they do not establish ownership in the same way as a Torrens title.

    The Court emphasized that the allegations in the complaint and the answer do not put in issue the existence and validity of the lease contract or their rental agreement. The petitioners never refuted the existence of a lease contract or the fact that they are merely renting the subject property. Likewise, the petitioners never deny their failure to pay rent. What the petitioners dispute is the respondent’s ownership of the subject property.

    FAQs

    What was the key issue in this case? The key issue was whether the respondent, as the registered owner of a property under the Torrens system, had the right to physical possession of the property in an unlawful detainer case.
    What is a Torrens title? A Torrens title is a certificate of title issued under the Torrens system, which is a land registration system that provides evidence of indefeasible ownership. It serves as proof of ownership and the right to possess the property.
    What is an unlawful detainer case? An unlawful detainer case is a legal action to recover possession of real property from someone who is unlawfully withholding possession after the expiration or termination of their right to possess it.
    Can a Torrens title be collaterally attacked in an unlawful detainer case? No, a Torrens title cannot be collaterally attacked in an unlawful detainer case. The validity of the title can only be challenged in a direct action filed for that purpose.
    What is the significance of a tax declaration in relation to a Torrens title? A tax declaration is a document that lists the assessed value of a property for taxation purposes. While it can be used to prove possession, it does not establish ownership in the same way as a Torrens title.
    What evidence did the respondent present to support her claim? The respondent presented a Transfer Certificate of Title (TCT) registered in her name, as well as tax declarations, to prove her ownership and right to possess the property.
    What was the main argument of the petitioners? The petitioners argued that the respondent was not the true owner of the property and that they had been authorized to occupy it by another individual.
    What did the Court rule regarding the demand letter and conciliation proceedings? The Court found that the petitioners’ claims that they did not receive the demand letter and that there was no prior conciliation proceeding were contradicted by the evidence on record.

    In conclusion, the Supreme Court’s decision in this case affirms the strength and reliability of the Torrens system in the Philippines. By prioritizing the Torrens title as evidence of ownership and the right to possession, the Court has provided clarity and guidance for resolving property disputes. This ruling reinforces the importance of registering property under the Torrens system to protect one’s rights and interests.

    For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

    Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
    Source: SPOUSES LOLITA ORENCIA AND PEDRO D. ORENCIA, VS. FELISA CRUZ VDA. DE RANIN, G.R. No. 190143, August 10, 2016