Aviles v. Court of Appeals
G.R. No. 95748 (November 21, 1996)
Facts:
The case involves a dispute over a parcel of land located in Malawa, Lingayen, Pangasinan, which the petitioners, Anastacia Vda. de Aviles and others, claim as their property. The land, which includes fishpond, cogonal, unirrigated rice, and residential areas, has an area of 18,900 square meters and was declared under Tax Declaration No. 31446. This property was part of the estate of the petitioners' deceased parents, Ireneo Aviles and Anastacia Salazar. The petitioners assert that since 1957, their father, Eduardo Aviles, was in actual possession of the property, which he even mortgaged to banks. During a bank inspection, Eduardo pointed out the boundaries of the property, which were not contested by the neighboring landowners, including the respondent, Camilo Aviles.
In 1983, Camilo Aviles began asserting a claim over a northern portion of the property, approximately 1,200 square meters, by constructing a bamboo fence and moving earthen dikes, thereby disturbing the petitioners' possession. Camilo admitted to an agreement of partition executed among him and his brothers, which allocated specific areas of their parents' property. However, he claimed that the disputed area was part of his share, while the petitioners contended it belonged to Eduardo Aviles.
The trial court dismissed the petitioners' complaint for quieting of title, ordering the parties to employ a land surveyor to determine the boundaries of the land. The petitioners appealed to the Court of Appeals, which affirmed the trial court's decision, stating that a quieting of title action was not the proper remedy for a boundary dispute.
Legal Issues:
- Is the special civil action of Quieting of Title under Rule 64 the proper remedy for settling a boundary dispute?
- Did the respondent Court err in not declaring the respective rights of the parties over the disputed property?
Arguments:
Petitioners' Arguments:
- The petitioners argue that the Court of Appeals erred in holding that a quieting of title action was not the proper remedy. They assert that Camilo Aviles' claim over the disputed lot is unfounded and that they have been in open, actual, continuous, peaceful, and adverse possession of the land.
- They question why Camilo waited 26 years to assert his claim and why he did not act when the property was mortgaged and subsequently redeemed by their mother.
Respondent's Arguments:
- Camilo Aviles contends that the petitioners fabricated claims regarding his encroachment and that he was merely repairing an existing fence.
- He argues that the trial court's decision to dismiss the complaint was justified, as the action for quieting of title does not address boundary disputes.
Court's Decision and Legal Reasoning:
The Supreme Court affirmed the decision of the Court of Appeals, agreeing that the action for quieting of title was not the appropriate remedy for the boundary dispute. The Court explained that quieting of title is a remedy to remove clouds or doubts on title to real property, which requires the existence of an instrument or claim that casts doubt on the title. In this case, the dispute was not about the validity of any title but rather about the location of the boundary between the properties of the parties.
The Court emphasized that the construction of the bamboo fence and the moving of earthen dikes did not constitute a cloud on the title of the petitioners. The uncertainty arose from the failure of the parties to properly measure and establish the boundaries of their respective properties. The Court cited precedents indicating that boundary disputes should be resolved through appropriate legal actions, such as ejectment or recovery of possession, rather than through a quieting of title action.
Regarding the second issue, the Court held that the trial court and the appellate court could not declare the respective rights of the parties in an action for quieting of title, as this would effectively determine ownership of the disputed property, which was not the purpose of such an action.
Significant Legal Principles Established:
- A special civil action for quieting of title is not the proper remedy for resolving boundary disputes.
- The existence of a cloud on title requires an instrument or claim that casts doubt on the title, which was not present in this case.
- Boundary disputes should be resolved through appropriate legal actions that allow for the introduction of evidence regarding possession and ownership.