CORNELIO DEL FIERRO, GREGORIO DEL FIERRO, ILDEFONSO DEL FIERRO, ASUNCION DEL FIERRO, CIPRIANO DEL FIERRO, MANUELA DEL FIERRO, AND FRANCISCO DEL FIERRO PETITIONERS, VS. RENE SEGU…

Del Fierro versus Seguiran

The Case

This is a case about land that slipped away because its owners could not prove it was theirs. The Del Fierro heirs sued Rene Seguiran for reconveyance of two agricultural lots in Palauig, Zambales, and for the cancellation of the free patent titles he had obtained over them. The Del Fierros claimed the lots had always belonged to their family and that Seguiran had fraudulently registered them in his own name. The case matters because it restates, in the clearest terms, the two things every plaintiff in a recovery of ownership must prove, and it shows how a winning ejectment case can still fail to win a reconveyance suit.

Procedural History

The Del Fierros filed their complaint for reconveyance and cancellation of titles before the Regional Trial Court of Iba, Zambales, Branch 71. The heirs of Francisco Santos intervened, claiming one of the lots. After trial, the court dismissed the complaint for insufficiency of evidence as to the identity of the properties sought to be recovered, and dismissed the complaint in intervention for prematurity and insufficiency of evidence. Both the plaintiffs and the intervenors appealed to the Court of Appeals, which affirmed the trial court in a decision dated October 2, 2001. Their motion for reconsideration was denied in a resolution dated February 11, 2002. The Del Fierros then came to the Supreme Court by petition for review on certiorari.

Facts

The subject of the case is two parcels of agricultural land, Lot 1625 and Lot 1626, situated in Locloc, Palauig, Zambales. In the cadastral survey conducted in December 1962, the records of the Lands Management Bureau showed conflicting claimants for the two lots, including Miguel del Fierro on one side and Lodelfo Marcial and others on the other.

In 1964 the Del Fierros, led by the widow of Miguel del Fierro, filed a forcible entry case against Lodelfo and Narciso Marcial. The municipal court ruled for the Del Fierros, and on appeal the Court of First Instance of Zambales sustained their right of possession in a decision dated August 1, 1973. Meanwhile, Lodelfo Marcial had mortgaged a parcel of land to the Rural Bank of San Marcelino, which foreclosed the mortgage and consolidated its ownership in 1982. In October 1981 Marcial sold Lots 1625 and 1626 to Rene Seguiran, and in November 1981 Seguiran also bought the foreclosed property from the bank. Seguiran then applied for a free patent, which the Bureau of Lands approved, and in July 1983 free patents were issued in his name. Original certificates of title were issued to him shortly after.

In September 1985 the Del Fierro heirs sued Seguiran for reconveyance and cancellation of titles, alleging fraud and bad faith in his patent application. The trial court and the Court of Appeals both found that the Del Fierros had failed to identify the land they were claiming. Their old Spanish deeds of sale and donation described properties in Barrio Liozon, while the lots in dispute are in Barrio Locloc, and their tax declarations did not designate the lots as Lot 1625 and Lot 1626 until 1985, the very year the lots were titled in Seguiran's name. The ejectment case, moreover, involved only Lot 1197, and there was no proof that the two lots formed part of it.

Issues

• Whether or not the Del Fierros are entitled to reconveyance of Lot 1625 and Lot 1626.
• Whether or not the certificates of title issued to Seguiran should be cancelled.
• Whether or not the Court of Appeals erred in affirming the dismissal on the ground of insufficiency of evidence as to the identity of the properties, an issue the petitioners say was never raised at trial.

Applicable Provisions

Article 434 of the Civil Code provides:

Article 434. In an action to recover, the property must be identified, and the plaintiff must rely on the strength of his title and not on the weakness of the defendant's claim.

This is the provision the Court applies to test whether the Del Fierros stated a cause for recovery of ownership, and it supplies the two requisites they failed to meet.

Ruling

On the first issue, the Court held that the Del Fierros failed to prove the identity of the land and their title to it. Under Article 434, a person claiming a better right to real property must prove two things: first, the identity of the land claimed, and second, his title thereto. In an action to recover, the claimant must first fix the identity of the land by describing its location, area, and boundaries. The Court found that the property in the ejectment case was Lot 1197, and neither the municipal court nor the Court of First Instance ever mentioned that the portion intruded upon was Lot 1625 or Lot 1626. The petitioners presented no technical description of Lot 1197 and proved no link between it and the disputed lots. Their Spanish deeds covered land in Barrio Liozon, not Barrio Locloc, and they could not establish which of those deeds, if any, covered the lots they were claiming.

On the second issue, the Court held that the certificates of title should not be cancelled, since the petitioners failed to prove by clear and convincing evidence that their issuance was attended by fraud. The Court also rejected the argument that the identity of the land was a new issue sprung on appeal. Having filed an action for reconveyance, it was incumbent on the petitioners to prove its requisites, one of which is the identity of the parcels claimed. Their failure to do so justified the dismissal of their complaint.

Doctrine

A plaintiff in an action to recover ownership of real property must prove two things: the identity of the land claimed, and his title thereto. Identity is fixed by describing the location, area, and boundaries of the property. The plaintiff must rely on the strength of his own title, not on the weakness of the defendant's claim. A party can claim a right of ownership only over the parcel of land that was the object of the deed. A judgment in a forcible entry case adjudicates only possession of the property described in that case, and it cannot establish ownership of different lots unless the claimant proves that those lots formed part of the land involved. Finally, a claim that a certificate of title was fraudulently obtained must be proved by clear and convincing evidence.

Disposition

The Supreme Court denied the petition and affirmed the decision of the Court of Appeals, so Seguiran kept his titles and the Del Fierros lost their case.

Remember This

Memorize the two requisites of Article 434: identify the land, and prove your title on your own strength. Examiners use this case to test whether a student knows that a winning ejectment suit over one lot proves nothing about ownership of another lot that the plaintiff never identified.