Case Digest: Mananquil vs Moico

G.R. No. 180076 : November 20, 2012




Lots 18 and 19 in Dagat-Dagatan, Navotas form part of the land previously expropriated by the National Housing Authority (NHA). Lots 18 and 19 were awarded to spouses Iluminardo and Prescilla Mananquil under a Conditional Contract to Sell.

After the death of the spouses in 1991, it turned out that Prescilla had a child by a previous marriagenamely Eulogio Francisco Maypa (Eulogio). Iluminardos supposed heirs (Mananquil heirs) his brothers and sisters and herein petitioners Dionisio and Estanislao Mananquil (Estanislao), Laudencia Mananquil-Villamor (Laudencia), and Dianita Mananquil-Rabino (Dianita) executed an Extrajudicial Settlement Among Heirs and adjudicated ownership over Lots 18 and 19 in favor of Dianita. They took possession of Lots 18 and 19 and leased them out to third parties.

Sometime later, the Mananquil heirs discovered that in 1997, Eulogio and two others, on the claim that they are surviving heirs of Iluminardo and Prescilla, had executed an Extrajudicial Settlement of Estate with Waiver of Rights and Sale, and a Deed of Absolute Sale in favor of Roberto Moico (Moico). Moico began evicting the Mananquils tenants. Thus, the Mananquils filed a case for quieting of title.

The RTC ruled in favor of the Mananquils. On appeal, the CA reversed the RTC.

The Mananquils argue that since they are the legal heirs of Iluminardo Mananquil, then they possess the requisite legal or equitable title or interest in Lots 18 and 19, which thus permits them to file an action to quiet title; and whatever rights Iluminardo had over the lots were transmitted to them from the moment of his death, per Article 777 of the Civil Code.

ISSUE: Whether or not the action to quiet title should prosper?

HELD: The petition lacks merit.

CIVIL LAW: quieting of title

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.

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 Iluminardos rights after his death.

Petitioners should have shown, to the satisfaction of the courts that under the NHA program project governing the grant of Lots 18 and 19, they are entitled and qualified to succeed or substitute for Iluminardo in his rights upon his death.