Facts:

The case involves a 21-hectare parcel of land located in Pawa-Talon and Guintoan, Palauig, Zambales, originally owned by Placido Miranda and his wife. After their deaths, the land was administered by their son, Maximo Miranda. On November 5, 1957, Maximo sold the land to Agerico Miranda, who was then the Provincial Treasurer of Zambales. Subsequently, on November 15, 1984, a Free Patent Title was issued to Agerico's daughter, Charito Miranda, who was residing in New Jersey, USA.

In December 1991, the heirs of Placido Miranda entered the land and prevented Agerico and Charito from cultivating it, claiming rightful ownership based on the assertion that Maximo was merely an administrator of Placido's estate. They alleged that Agerico had fraudulently prepared a tax declaration that misrepresented Maximo as the sole owner.

In response, Agerico and Charito filed a forcible entry action in the Municipal Circuit Trial Court (MCTC) of Masinloc and Palauig, which was initially dismissed for lack of jurisdiction. However, upon appeal, the Regional Trial Court (RTC) reversed this dismissal, leading to a judgment in favor of Agerico and Charito, ordering the heirs to vacate the land.

Simultaneously, the heirs filed a complaint for annulment of the sale, claiming it was fraudulent and that Charito, as a foreign citizen, was disqualified from owning land in the Philippines. The RTC dismissed this complaint on the grounds of prescription, as the heirs filed their complaint nearly 35 years after the sale.

Legal Issues:

  1. Whether the heirs' action for annulment of the sale was barred by prescription.
  2. Whether the MCTC properly applied summary procedure in the ejectment case despite the ownership dispute.
  3. Whether the heirs were denied due process by the dismissal of their complaint without a full hearing.

Arguments:

Petitioners (Heirs of Placido Miranda):

  • They argued that the sale of the land was fraudulent and therefore void, and that they had a right to annul the sale within four years from the time they discovered the fraud in November 1991.
  • They contended that the MCTC should not have used summary procedure because ownership was in question, and they were denied due process as they were not allowed to present evidence.

Respondents (Agerico and Charito Miranda):

  • They maintained that they had been in continuous possession of the land since 1957, and that the heirs' claim was barred by prescription, as the heirs filed their complaint 35 years after the sale.
  • They argued that the summary procedure was appropriate for ejectment cases, regardless of ownership claims, and that the heirs' action for annulment did not prevent the ejectment proceedings.

Court's Decision and Legal Reasoning:

The Supreme Court dismissed both petitions for review, affirming the decisions of the Court of Appeals. The Court held that:

  1. The heirs' action for annulment was indeed barred by prescription. The sale occurred in 1957, and the heirs did not file their complaint until 1992, well beyond the 30-year period for extraordinary prescription. The Court noted that the heirs' claim of fraud did not negate the effects of prescription once it had set in.

  2. The MCTC correctly applied the summary procedure in the ejectment case. The Revised Rules on Summary Procedure allowed for such cases to proceed without a hearing, focusing instead on affidavits and position papers. The Court clarified that the existence of an ownership dispute does not preclude the MCTC from adjudicating ejectment cases.

  3. The Court found no violation of due process, as the heirs had ample opportunity to present their arguments against the motion to dismiss. The dismissal was based on the clear evidence of prescription, and the trial court was not required to hold a hearing for oral testimonies in this instance.

Significant Legal Principles Established:

  • Acquisitive prescription can bar actions for annulment of sale if the period for filing such actions has lapsed.
  • Ejectment cases can proceed under summary procedure even when ownership is contested, as the primary issue is possession.
  • The remedies of appeal and certiorari are mutually exclusive; certiorari cannot substitute for an appeal when the latter is available.