Mananquil vs Moico
GR No. 180076 November 21, 2012
Facts: Lots 18 and 19 in Dagat-Dagatan, Navotas form part of the land previously expropriated by the National Housing Authority (NHA) and placed under its Tondo Dagat-Dagatan Foreshore Development Project – where occupants, applicants or beneficiaries may purchase lots on installment basis. In October 1984, Lot 18 was awarded to spouses Iluminardo and Prescilla Mananquil under a Conditional Contract to Sell. Lot 19, on the other hand, was sold to Prescilla in February 1980 by its occupant. When the spouses died, the heirs of Illuminardo filed for extrajudicial settlement of estates of the spouses over lots 18 and 19. They appropriated to themselves the properties by leasing it. However, herein respondent Moico bought the properties from one Eulogio who is the alleged child of Prescilla from her first marriage who in turn evicted the tenants of the herein petitioners. Upon finding out the of the same, the Mananquils filed for an action to quiet the title against herein Moico claiming title over the said properties.
Issue: Whether or not petitioners have legal title over the subject lots entitling for the relief of quieting of title.
Held: No. An action for quieting of title is essentially a common law remedy grounded on equity.
The competent court is tasked to determine the respective rights of the complainant and other claimants, not only to place things in their proper place, to make the one who has no rights to said immovable respect and not disturb the other, but also for the benefit of both, so that he who has the right would see every cloud of doubt over the property dissipated, and he could afterwards without fear introduce the improvements he may desire, to use, and even to abuse the property as he deems best. But “for an action to quiet title to prosper, two indispensable requisites must concur, namely:
(1) the plaintiff or complainant has a legal or an equitable title to or interest in the real property subject of the action; and
(2) the deed, claim, encumbrance, or proceeding claimed to be casting cloud on his title must be shown to be in fact invalid or inoperative despite its prima facie appearance of validity or legal efficacy.”
Contrary to petitioners’ stand, the issue relating to the grant of rights, title or award by the NHA determines whether the case for quieting of title may be maintained. If the petitioners are legitimate successors to or beneficiaries of Iluminardo upon his death – under the certificate of title, award, or grant, or under the special law or specific terms of the NHA program/project – then they possess the requisite interest to maintain suit; if not, then Civil Case No. 2741-MN must necessarily be dismissed.
From the evidence adduced below, it appears that the petitioners have failed to show their qualifications or right to succeed Iluminardo in his rights under the NHA program/project. They failed to present any title, award, grant, document or certification from the NHA or proper government agency which would show that Iluminardo and Prescilla have become the registered owners/beneficiaries/ awardees of Lots 18 and 19, or that petitioners are qualified successors or beneficiaries under the Dagat-Dagatan program/project, taking over Iluminardo’s rights after his death. They did not call to the witness stand competent witnesses from the NHA who can attest to their rights as successors to or beneficiaries of Lots 18 and 19. They failed to present proof, at the very least, of the specific law, provisions, or terms that govern the Tondo Dagat-Dagatan Foreshore Development Project which would indicate a modicum of interest on their part. For this reason, their rights or interest in the property could not be established.