Del Fierro v. Seguiran

G.R. No. 152141 (August 8, 2011)

Miguel del Fierro's heirs lost land reconveyance; Rene Seguiran's titles upheld as valid.

Facts:

The case involves a dispute over two parcels of agricultural land, Lot Nos. 1625 and 1626, located in Locloc, Palauig, Zambales, with a total area of approximately 188,924 square meters. The cadastral survey for these lots was conducted in December 1962. The claimants for Lot No. 1625 were Lodelfo Marcial against Miguel del Fierro, while for Lot No. 1626, the claimants were Lodelfo Marcial against Francisco Santos and Narciso Marcial.

In 1964, Francisco Santos applied for a free patent over Lot No. 1626, but the application remained pending until 1985. Meanwhile, the heirs of Miguel del Fierro filed an ejectment case against Lodelfo Marcial in 1964, which resulted in a decision favoring the Del Fierros in 1972. The ejectment case involved Lot No. 1197, and the court ordered the Marcials to vacate the premises.

In 1972, Lodelfo Marcial mortgaged a different parcel of land to the Rural Bank of San Marcelino, which was subsequently foreclosed in 1982. On October 28, 1981, Lodelfo Marcial executed a Deed of Absolute Sale in favor of Rene Seguiran for Lot Nos. 1625 and 1626. Seguiran later purchased the foreclosed property from the bank and applied for free patents, which were granted in 1983, leading to the issuance of Original Certificates of Title in his name.

In 1985, the heirs of Miguel and Generosa del Fierro filed a complaint for reconveyance and cancellation of titles against Seguiran, claiming ownership of Lot Nos. 1625 and 1626. They argued that Marcial had no legal right to sell the lots as he was a deforciant, and that Seguiran acted in bad faith by securing the titles despite the ongoing legal controversy.

The trial court dismissed the complaint for insufficiency of evidence regarding the identity of the properties. The Court of Appeals affirmed this decision, leading to the present petition for review.

Legal Issues:

  1. Whether the petitioners are entitled to reconveyance of Lot Nos. 1625 and 1626.
  2. Whether the certificates of title issued to the respondent should be cancelled.

Arguments:

Petitioners' Arguments:

  • The petitioners claimed ownership of Lot Nos. 1625 and 1626 based on their possession and the favorable decision in the ejectment case, which they argued established their right to the properties.
  • They contended that the respondent acted in bad faith by applying for free patents while knowing that the properties were subject to legal dispute.
  • They asserted that the respondent's titles were obtained through fraudulent means, as he misrepresented his possession of the land.

Respondent's Arguments:

  • The respondent argued that he acquired the properties legally through a valid sale from Marcial and the subsequent purchase from the Rural Bank.
  • He maintained that the petitioners failed to prove the identity of the properties they claimed, as the evidence presented did not establish a clear connection between Lot Nos. 1625 and 1626 and the properties referenced in the ejectment case.
  • The respondent also contended that the petitioners' claims were barred by the principle of exhaustion of administrative remedies, as the intervenors had pending administrative protests regarding the free patent.

Court's Decision and Legal Reasoning:

The Supreme Court affirmed the decision of the Court of Appeals, which upheld the trial court's dismissal of the petitioners' complaint. The Court reasoned that the petitioners failed to establish the identity of the properties they sought to recover. The evidence presented indicated that the properties in the Spanish deeds of conveyance were located in Barrio Liozon, while Lot Nos. 1625 and 1626 were situated in Barrio Locloc. The Court emphasized that the petitioners did not provide sufficient evidence to demonstrate that Lot Nos. 1625 and 1626 were part of Lot No. 1197, which was the subject of the ejectment case.

The Court also noted that the petitioners could not rely on the decision from the ejectment case to assert ownership over Lot Nos. 1625 and 1626, as that case only addressed possession of Lot No. 1197. Furthermore, the Court found no evidence of fraud in the issuance of the titles to the respondent, as he had secured a certification from the court indicating no pending cases involving the properties at the time of his application for free patents.

Significant Legal Principles Established:

  • The requisites for reconveyance under Article 434 of the Civil Code require the claimant to prove both the identity of the land claimed and their title to it.
  • In an action for reconveyance, the burden of proof lies with the claimant to establish the identity of the property and the basis of their ownership.
  • The principle of exhaustion of administrative remedies applies in cases involving the cancellation of free patents, requiring parties to pursue administrative channels before seeking judicial relief.