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Clado-Reyes V Limpe Digest

The court ruled in favor of the respondents for the following reasons: 1. The petitioners did not provide sufficient evidence to prove they had legal title to the disputed lot, while the respondents presented documentation like a certificate of title and tax declarations registered in their name. 2. The documents presented by the petitioners purportedly showing a transfer of title were deemed hearsay and did not actually indicate a transfer of ownership. 3. Under the Torrens system, the respondents' certificate of title enjoys a conclusive presumption of validity as proof of ownership. As such, the court found the respondents had superior title to the disputed lot.

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188 views2 pages

Clado-Reyes V Limpe Digest

The court ruled in favor of the respondents for the following reasons: 1. The petitioners did not provide sufficient evidence to prove they had legal title to the disputed lot, while the respondents presented documentation like a certificate of title and tax declarations registered in their name. 2. The documents presented by the petitioners purportedly showing a transfer of title were deemed hearsay and did not actually indicate a transfer of ownership. 3. Under the Torrens system, the respondents' certificate of title enjoys a conclusive presumption of validity as proof of ownership. As such, the court found the respondents had superior title to the disputed lot.

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Princess Loyola Tapia
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Clado-Reyes vs.

Limpe
G.R. No. 163876 July 9, 2008

Facts:
On February 1, 1995, petitioners filed an action to quiet title, reconveyance and damages against
respondents and alleged that they have been occupying the disputed lot since 1945 through their
predecessor-in-interest, Mamerto B. Reyes. They claimed that during his lifetime, Mamerto had
accepted a verbal promise of the former lot owner, Felipe Garcia, to give the disputed lot to him
in exchange for the surrender of his tenancy rights as a tiller thereof.
To prove that Mamerto was a former tenant of Felipe; that during his lifetime he had worked on
the lot; and that he owned and possessed the same, petitioners presented two documents, namely:
(1) Certification dated October 12, 1979 and (2) “Pagpapatunay” dated November 17, 1982
allegedly executed by Simeon I. Garcia, the eldest son of Felipe, attesting to such facts.
Petitioners also alleged that whenever respondents visited the lot, respondent Julius Limpe would
promise to deliver the certificate of title to them. However, sometime in October 1994,
petitioners received a letter from respondents asserting ownership over the disputed lot.
In their answer, respondents contended that they are the legal owners of the lot by virtue of a
Deed of Exchange of Real Estate and Deed of Absolute Sale executed on July 5, 1974 and
February 28, 1974, respectively, between them and Farm-Tech Industries, Incorporated. To
further assert ownership over the lot, they presented TCT No. T-199627, Tax Declaration Nos.
1517212 and 952913 and realty tax receipts14 of the lot, which were all registered and declared
in their names.
In its Decision dated January 9, 2001, the trial court ruled in favor of respondents and held that
the certificate of title, tax declarations and realty tax receipts presented in court indisputably
established respondents’ ownership over the lot. The certificate of title was registered in
respondents’ names and the realty tax receipts showed that respondents consistently paid the
corresponding real property taxes. These pieces of evidence, said the trial court, prevail over
petitioners’ allegation of an “undocumented promise” by the former lot owner, which in itself, is
ineffective or unenforceable under the law. Accordingly, the trial court ordered petitioners to
reconvey the disputed lot to respondents.
The trial court ruled in favor of respondents. Accordingly, the trial court ordered petitioners to
reconvey the disputed lot to respondents. The CA affirmed the trial court’s ruling and upheld
respondent’s title over the disputed lot. Hence the petition.
Issue:
Whether the petitioners have a cause of action to quiet title, reconveyance and damages against
respondents.
Held:
The court ruled that the petition lacks merit.
Under Article 476 and 477 of the New Civil Code, there are two indispensable requisites in order
that an action to quiet title could prosper: (1) that the plaintiff or complainant has a legal or an
equitable title to or interest in the real property subject of the action; and (2) that 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.
To prove their case, petitioners merely cited Section 4 of Article XIII of the 1987 Constitution
and Section 2 of the Comprehensive Agrarian Reform Law and stated that their title was founded
upon those provisions.  They hardly argued on the matter.  Neither was there positive evidence
(1) that their predecessor had legal title, i.e., a certificate of land transfer; a (2) that the lot was an
agricultural lot and not a commercial one as contended by respondents; and (3) that they are
qualified beneficiaries under the Agrarian Reform Law.  Time and again we have held that a
mere allegation is not evidence, and he who alleges has the burden of proving the allegation with
the requisite quantum of evidence.

Next, the documentary evidence petitioners presented, namely, the "Certification" and
"Pagpapatunay," did not confirm their title over the disputed lot.  First, original copies of those
documents were not presented in court. Second, as the appellate court pointed out, Simeon I.
Garcia, the declarant in those documents, was not presented in court to prove the veracity of their
contents. Third, even a cursory examination of those documents would not show any transfer or
intent to transfer title or ownership of the disputed lot from the alleged owner, Felipe Garcia, to
petitioners or their predecessor-in-interest, Mamerto B. Reyes.  Fourth, petitioners did not bother
to adduce evidence that Simeon I. Garcia, as the eldest son of the late Felipe Garcia, inherited the
entire lot as to effectively convey title or ownership over the disputed lot, i.e. thru extrajudicial
settlement of the estate of the late Felipe Garcia.  Accordingly, we agree that the documents
allegedly executed by Simeon I. Garcia are purely hearsay and have no probative value.

In contrast, respondents presented evidence which clearly preponderates in their favor.  First, the
transfer certificate of title, tax declarations and realty tax receipts were all in their names. 
Second, pursuant to the Torrens System, TCT No. RT-32498 (T-199627) enjoys the conclusive
presumption of validity and is the best proof of ownership of the lot.  Third, although tax
declarations or realty tax receipts are not conclusive evidence of ownership, nevertheless, they
are good indicia of possession in the concept of an owner, for no one in his right mind would be
paying taxes for a property that is not in his actual or at least constructive possession.  As we
previously held, such realty tax payments constitute proof that the holder has a claim of title over
the property.

Worth stressing, in civil cases, the plaintiff must establish his cause of action by preponderance
of evidence; otherwise, his suit will not prosper. After carefully considering the arguments of the
parties, as well as their respective evidence, we unanimously agree that the petitioners were not
able to prove that they have any legal or equitable title over the disputed lot.  Thus, we find no
reversible error in the assailed decisions of the courts below.

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