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.”[7]
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.
It was erroneous, however, for the CA to assume that Iluminardo and Prescilla may have violated the conditions of the NHA grant under the Tondo Dagat-Dagatan Foreshore Development Project by transferring their rights prior to the issuance of a title or certificate awarding Lots 18 and 19 to them. In the absence of proof, a ruling to this effect is speculative. Instead, in resolving the case, the trial court – and the CA on appeal – should have required proof that petitioners had, either: 1) a certificate of title, award, or grant from the proper agency (NHA or otherwise) in the name of their predecessor Iluminardo, or, in the absence thereof, 2) a right to succeed to Iluminardo’s rights to Lots 18 and 19, not only as his heirs, but also as qualified legitimate successors/beneficiaries under the Tondo Dagat-Dagatan Foreshore Development Project terms and conditions as taken over by the NHA.[8] 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. As earlier stated, this takes the form of evidence – apart from proof of heirship, of course – of the specific law, regulation or terms covering the program/project which allows for a substitution or succession of rights in case of death; the certificate of title, award or grant itself; or the testimony of competent witnesses from the NHA.
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.
It was erroneous, however, for the CA to assume that Iluminardo and Prescilla may have violated the conditions of the NHA grant under the Tondo Dagat-Dagatan Foreshore Development Project by transferring their rights prior to the issuance of a title or certificate awarding Lots 18 and 19 to them. In the absence of proof, a ruling to this effect is speculative. Instead, in resolving the case, the trial court – and the CA on appeal – should have required proof that petitioners had, either: 1) a certificate of title, award, or grant from the proper agency (NHA or otherwise) in the name of their predecessor Iluminardo, or, in the absence thereof, 2) a right to succeed to Iluminardo’s rights to Lots 18 and 19, not only as his heirs, but also as qualified legitimate successors/beneficiaries under the Tondo Dagat-Dagatan Foreshore Development Project terms and conditions as taken over by the NHA.[8] 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. As earlier stated, this takes the form of evidence – apart from proof of heirship, of course – of the specific law, regulation or terms covering the program/project which allows for a substitution or succession of rights in case of death; the certificate of title, award or grant itself; or the testimony of competent witnesses from the NHA.
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