IN THE MATTER OF: ANNULMENT OF TRANSFER CERTIFICATES OF TITLE NOS. M-9876, M-9877, M-29530, M-9874, LOCATED IN BO. TUGATOG AND TENEJEROS, MALABON, METRO MANILA, AND ANY AND/OR D…

Sevilla versus Spouses Lim

The Case

This is the case of Sevilla versus Spouses Lim. A man acting as attorney-in-fact of Lilia D. Sevilla asked the Regional Trial Court of Malabon City to declare several transfer certificates of title spurious and void, and to revert the lands they cover to what he claimed was the mother title, Original Certificate of Title Number 994 of the Maysilo Estate. The persons holding those titles, among them the Spouses Lim, the Spouses Villanueva, and Myra Sevilla, resisted. The case matters because it turns on a single, settled fact about the Maysilo Estate: there is only one valid Original Certificate of Title Number 994, and it was registered on the third of May 1917, not on the nineteenth of April 1917. It is also a clean teaching case on the elements of a cause of action.

Procedural History

The petitioner filed his petition before the Regional Trial Court of Malabon City, Branch 74. The private respondents moved to dismiss on the ground that the petitioner had no legal capacity to sue and that the petition stated no cause of action. In an Order dated the twelfth of September 2012, the trial court granted the motion and dismissed the case for lack of cause of action. The petitioner moved for reconsideration, and the trial court denied the motion in an Order dated the fourteenth of May 2013. The petitioner then appealed to the Supreme Court. The respondents filed their briefs, and after the parties exchanged submissions the case was deemed submitted for decision without a reply brief from the petitioner.

Facts

The petitioner claimed to be the attorney-in-fact of Lilia D. Sevilla, who, he said, bought several parcels of land in the Maysilo Estate by a Deed of Absolute Sale executed on the fourteenth of January 1977, for which she paid the pro-indiviso owners sixty thousand pesos. Those parcels, he said, were originally registered on the nineteenth of April 1917 as Original Certificate of Title Number 994. He insisted that Lilia Sevilla never sold or conveyed the properties to the respondents or their predecessors, and he pointed to supposed irregularities in the records to show that the respondents' titles were spurious.

The respondents traced their own titles to a different Original Certificate of Title Number 994, this one registered on the third of May 1917. The Spouses Lim said they bought their land from a bank, which had acquired it through an extrajudicial foreclosure sale. The Spouses Villanueva and Myra Sevilla answered that the subdivision plan the petitioner relied on covered land in Cebu City, while the plan controlling their titles covered land in Malabon City. They added that a civil case decided by the Regional Trial Court of Kalookan City, Branch 122, had already declared void the Original Certificate of Title Number 994 dated the nineteenth of April 1917, and void as well the very Deed of Absolute Sale on which the petitioner relied.

The trial court dismissed the petition for lack of cause of action, and denied reconsideration. Hence the appeal.

Issues

• Whether or not the petitioner, as attorney-in-fact of Lilia D. Sevilla, established a cause of action for the cancellation of the respondents' transfer certificates of title and the reversion of the properties to Original Certificate of Title Number 994.
• Whether or not the trial court erred in dismissing the petition without a full-blown trial.
• Whether or not the respondents' titles, traced to Original Certificate of Title Number 994 dated the third of May 1917, are valid as against the petitioner's claim, which is traced to the Original Certificate of Title Number 994 dated the nineteenth of April 1917.

Applicable Provisions

Section 2, Rule 2 of the Rules of Court defines a cause of action, and the Court quotes it in defining the term:

Section 2, Rule 2 of the Rules of Court defines a cause of action as an act or omission by which a party violates a right of another.

This definition supplies the test the Court applies: without a violation of the petitioner's right by the respondents, there is no cause of action and the petition cannot stand.

Ruling

On the first issue, the Court held that the petitioner failed to establish a cause of action. The Court laid out the essential elements of a cause of action: a right in favor of the plaintiff; an obligation on the part of the defendant to respect that right; and an act or omission of the defendant in violation of that right. The Court found that the petitioner failed to establish the third element. His claim rested on titles derived from Original Certificate of Title Number 994 dated the nineteenth of April 1917, and that mother title had already been declared null and void by the Supreme Court. The Court took judicial notice that the Maysilo Estate has spawned many cases of overlapping titles, some tracing to the nineteenth of April 1917 and some to the third of May 1917, and it recalled its earlier rulings upholding the titles traced to the third of May 1917 and voiding those traced to the nineteenth of April 1917. It quoted the findings it had adopted:

As categorically declared by the Supreme Court, there is only one OCT 994, the registration date of which had already been decisively settled as 3 May 1917 and not 19 April 1917. OCT 994 which reflects the date of 19 April 1917 as its registration date is null and void.

The Court added that even if the nineteenth of April 1917 title were valid, the petition would still fail, because the Deed of Absolute Sale on which the petitioner relied had never been registered, and so could not prevail over the respondents' registered titles.

On the second issue, the Court held that no full-blown trial was needed. From the allegations of the petition and the unregistered deed attached to it, weighed against the respondents' registered titles, the trial court could safely conclude that the petitioner had failed to establish a cause of action and that the allegations could not sustain the relief prayed for.

On the third issue, the Court held that the respondents' titles, traced to Original Certificate of Title Number 994 registered on the third of May 1917, stand, while the petitioner's claim, rooted in the void nineteenth of April 1917 title, must fall.

Doctrine

A cause of action has three essential elements: a right in favor of the plaintiff; an obligation on the part of the defendant to respect that right; and an act or omission of the defendant in violation of that right. The absence of the third element means there is no cause of action, and a motion to dismiss lies. On the Maysilo Estate, there is only one valid Original Certificate of Title Number 994, registered on the third of May 1917; the certificate bearing the date nineteenth of April 1917 is null and void and vests no right. Finally, an unregistered deed of sale cannot defeat registered titles.

Disposition

The Supreme Court denied the appeal and affirmed the Orders of the Malabon City Regional Trial Court dismissing the petition, so the private respondents prevailed.

Remember This

Memorize the line: there is only one Original Certificate of Title Number 994, registered on the third of May 1917, and the nineteenth of April 1917 title is void. Examiners use this case for the elements of a cause of action and for Maysilo Estate title questions.