G.R. No. 181596 , January 30, 2017
JENESTOR B. CALDITO and MARIA FILOMENA T. CALDITO, Petitioners, vs. ISAGANI V. OBANDO and GEREON V. OBANDO, Respondents.

FACTS

The petitioners, Spouses Caldito, filed a complaint for quieting of title over a portion of Lot No. 1633 in Sarrat, Ilocos Norte. They claimed ownership by virtue of a 1995 Deed of Absolute Sale executed by Spouses Antonio and Elena Ballesteros. Antonio Ballesteros had executed an affidavit claiming the lot was co-owned by Felipe Obado and his siblings, from whom he allegedly derived his right. The petitioners subsequently declared the lot for taxation and paid taxes. In 2002, they attempted to build on the land but were prevented by the respondents, who are the sons of Paterno Obado.
The respondents asserted ownership, claiming their father Paterno inherited the entire Lot No. 1633 from its original owner, Felipe Obado, whom Paterno treated as a father. They argued they and their predecessors had been in open, continuous, and peaceful possession of the entire lot since 1969, paying real property taxes. They contended the Spouses Ballesteros had no valid title to convey and that the petitioners were buyers in bad faith.

ISSUE

Whether the petitioners have established a valid claim of ownership over the subject portion of Lot No. 1633 sufficient to sustain an action for quieting of title.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals’ ruling. The legal logic centers on the failure of the petitioners to prove their alleged ownership or equitable title, which is a prerequisite for the action of quieting of title. An action to quiet title requires the plaintiff to have a legal or equitable title to the property. The Court found the petitioners’ evidence utterly insufficient. The Affidavit of Ownership by Antonio Ballesteros, which was the foundational claim of co-ownership by Felipe Obado’s siblings, was hearsay as he was never presented to testify. The Deed of Absolute Sale from the Ballesteros couple, by itself, did not prove the vendors had any transferable right or title to the property.
Conversely, the respondents’ long-standing, open, and continuous possession since 1969, coupled with their payment of taxes, enjoyed the presumption of just title in their favor. The petitioners, as buyers of unregistered land, were charged with the duty to investigate the title of their vendors, especially since the lot was in the possession of persons other than the vendors. Their failure to do so rendered them not innocent purchasers for value. Since the Spouses Ballesteros had no proven right to sell, the petitioners acquired nothing. Therefore, lacking any valid title, their action for quieting of title must fail.