Primary Holding

The petition is granted. The decisions of the Court of Appeals and the Regional Trial Court are reversed and set aside. The complaint of the respondent is dismissed. The respondent failed to implead indispensable parties and failed to prove his claim of ownership by preponderance of evidence sufficient to overcome the petitioners' Torrens title.

Background

Alfredo Hular claimed ownership of land originally owned by his father, Astrologo Hular, part of Lot No. 3347. He alleged that Iluminado Baloloy fraudulently secured a Free Patent and OCT over Lot No. 3353, which included a portion of his father's land (later found to be 1,405 square meters, not 287 sqm as initially thought). Hular sought to quiet title, nullify the Baloloy's OCT, and reconveyance, citing prior ownership and acquisitive prescription. Baloloys, heirs of Iluminado, argued their title's sanctity and Hular's lack of cause of action.

Facts

• 1. Spouses Lino and Victoriana Estopin originally owned Lot No. 3347.
• 2. Victoriana Lagata (widow of Lino) sold portions of Lot No. 3347 to Astrologo Hular in 1961.
• 3. Irene Griarte owned a land that became Lot No. 3353 and sold it to Martiniano Balbedina in 1945, who later sold it to Iluminado Baloloy in 1951.
• 4. Iluminado Baloloy obtained a Free Patent and OCT No. P-16540 for Lot No. 3353 in 1968.
• 5. Alfredo Hular claimed his father Astrologo purchased a portion of Lot No. 3347 from Lagata.
• 6. Hular alleged Baloloy’s Free Patent fraudulently included part of his father’s land.
• 7. Survey in 1993 revealed Hular’s house was on Lot No. 3353, covered by Baloloy’s OCT.
• 8. Disputed area was determined to be 1,405 square meters, part of Lot No. 3353.
• 9. Hular and Baloloys' houses were near each other, initially believed to be on different lots (3347 and 3353).

Arguments of the Petitioners

• 1. Respondent failed to implead indispensable parties: his siblings as co-owners and the Republic of the Philippines as the grantor of the Free Patent.
• 2. Respondent lacked cause of action to nullify the Free Patent and OCT; only the State can directly annul a patent.
• 3. Respondent failed to prove his father’s ownership over the disputed portion of land.
• 4. Victoriana Lagata sold a portion of Lot No. 3347, but Hular built on Lot No. 3353, covered by Baloloy's title.
• 5. Torrens title (OCT No. P-16540) held by Iluminado Baloloy is indefeasible and should prevail.
• 6. Action for nullification and reconveyance had prescribed.

Arguments of the Respondents

• 1. His father acquired the land from Victoriana Lagata (Estopin).
• 2. Iluminado Baloloy fraudulently obtained a Free Patent that included his father's land.
• 3. He and his predecessors had been in possession of the land for over 60 years, acquiring ownership through acquisitive prescription.
• 4. Victoriana Lagata was unaware that the land she sold to Hular was declared part of Lot 3353 when Juban lands were surveyed.

Issues

• 1. Whether all indispensable parties were impleaded by the respondent.
• 2. Whether the respondent had a cause of action to nullify Free Patent No. 384019 and OCT No. P-16540 and for reconveyance and possession.
• 3. Whether the respondent acquired ownership through acquisitive prescription.

Ruling

• 1. The Supreme Court ruled in favor of the petitioners (Baloloys).
• 2. Respondent Hular failed to implead indispensable parties: his siblings (co-owners of Astrologo Hular’s estate) and the Republic of the Philippines (regarding nullification of the Free Patent).
• 3. Absence of indispensable parties renders all proceedings ineffective.
• 4. Respondent failed to prove his claim of ownership with sufficient evidence to overcome the petitioners' Torrens title. He did not present the deed of sale from Irene Griarte to Lino Estopin or relevant tax declarations.
• 5. The Torrens title of Iluminado Baloloy prevails in the absence of strong evidence to the contrary.
• 6. Respondent’s action was essentially a reinvidicatory action and publiciana, requiring him to prove ownership which he failed to do adequately.

Doctrines

• 1. Indispensable Parties: Parties with such an interest in the controversy that a final decree cannot be made without affecting their rights. Their absence renders the judgment void. (Rule 3, Section 7 of the Rules of Court).
• 2. Torrens System and Indefeasibility of Title: A Torrens Certificate of Title is evidence of indefeasible title. The registered owner is presumed to be the owner, and this title is generally binding and conclusive.
• 3. Burden of Proof: The plaintiff has the burden of proving their claim by the requisite quantum of evidence.
• 4. Nemo dat quod non habet: "No one can give what they do not have." Lagata could not sell what she did not own (portion of Lot 3353).

Key Excerpts

• 1. "The burden of proof is on the plaintiff to establish his case by the requisite quantum of evidence."
• 2. "A Torrens Certificate is evidence of an indefeasible title to property in favor of the person in whose name appears therein."
• 3. “NEMO DAT QUOD NON HABET.”

Precedents Cited

• 1. Villegas v. Court of Appeals: Cited regarding the importance of resolving issues interwoven with other raised issues and decisive of the outcome of the case.
• 2. Salvador v. Court of Appeals: Cited regarding the effect of the absence of indispensable parties rendering proceedings ineffective.
• 3. Belo and Trust Company v. Alejo: Cited on the same point as Salvador v. Court of Appeals regarding indispensable parties.
• 4. Heirs of Fabella v. Court of Appeals: Cited on the burden of proof for the plaintiff.
• 5. Ray v. Court of Appeals: Cited on the requirement for someone claiming a better right to real estate to prove ownership and identity of the land.
• 6. Huy v. Huy: Cited regarding the presumptive conclusiveness of a Torrens title and the weight it should be given.
• 7. Republic v. Court of Appeals: Cited on the strength and weight given to Torrens titles.
• 8. Urquiaga v. Court of Appeals: Cited to support the ruling that boundaries in a cadastral survey are definitive, and adjacent owners cannot claim beyond their titled property.
• 9. Veterans Federation of the Philippines v. Court of Appeals: Cited regarding deeds of sale being valid and enforceable based on the described object of the sale, not later claims of erroneous descriptions in titles.
• 10. Serna v. Court of Appeals: Cited for the evidentiary value of tax declarations for ownership.

Statutory and Constitutional Provisions

• 1. Rule 45 of the Revised Rules of Court (Petition for Review on Certiorari).
• 2. Rule 3, Section 7 of the Rules of Court (Indispensable Parties).
• 3. Article 1078 of the Civil Code (Co-ownership of Heirs before Partition).
• 4. Article 487 of the New Civil Code (Action by Co-owner).
• 5. Section 9, Rule 130 of the Rules of Court (Evidence of Written Agreements).