Professional Documents
Culture Documents
CABRAL (2013)
Petitioners: Green Acres
Respondents: Victoria Cabral, Sps. Moraga, Department of Agrarian
Reform Adjudication Board (DARAB)
DOCTRINE: For an action to quiet title to prosper, two indispensable
requisites must concur: (1) the plaintiff or complainant has a legal or
equitable title or interest in the real property subject of the action; and
(2) the deed, claim, encumbrance, or proceeding claimed to be casting
a cloud on his title must be shown to be in fact invalid or inoperative
despite its prima facie appearance of validity or legal efficacy.
(2nd req) Cloud on title consists of (1) any instrument, record, claim,
encumbrance or proceeding; (2) which is apparently valid or effective;
(3) but is in truth and in fact invalid, ineffective, voidable, or
unenforceable; and (4) may be prejudicial to the title sought to be
quieted.
FACTS:
1. Victoria Cabral was the original owner of a parcel of land in Meycauayan,
Bulacan covered by a TCT Certificate.
2. The land was placed under the coverage of PD 27 and 3 Emancipation
Patents were issued to the Sps. Moraga.
3. Cabral filed a complaint before the Provincial Agrarian Reform
Adjudicator (PARAD) to cancel the emancipation patents in favor of Sps.
Moraga on the ground that they were obtained through fraud; properties
were not agricultural lands but classified as residential, commercial,
industrial land by the Housing and Land Use Regulatory Board.
a. PARAD: denied
4. Pending appeal of Cabral, Sps. Morga subdivided the lot into 3 smaller
lots each with a TCT and sold the properties to Filcon Ready Mixed Inc.,
which the latter then sold to Green Acres.
a. Aside from a cancelled annotation of a real estate mortgage in
favor of PCI Bank, the titles were free from any annotations, liens,
notices, claims or encumbrances.
b. titles under the name of Filcon were cancelled by RD and new
titles were issued in the name of Green Acres
5. Thereafter, DARAB rendered judgment on the appeal of Cabral (PARAD
case), ordering the cancellation of the titles in the name of Sps. Moraga
and Filcon for having been illegally acquired.
6. Green Acres, upon knowledge of the DARAB decision and fearing that its
titles and possession might be disturbed by the decision, sent a letter to
Filcon reminding the latter of its warranties under the deed of sale.
a. Filcon: it was also an innocent purchaser for value; bought property
without knowledge of any legal infirmity on the title.
RULING + RATIO:
Record - a written account of some act, court proceeding, transaction or instrument drawn
up under authority of law, by a proper officer, and designed to remain as a memorial or
permanent evidence of the matters to which it relates.
Claim - a cause of action or a demand for money or property since Cabral is asserting her
right over the subject lots.
Proceeding - a regular and orderly progress in form of law including all possible steps in
an action from its commencement to the execution of judgment and may refer not only to
a complete remedy but also to a mere procedural step that is part of a larger action or
special proceeding.