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G.R. No. 198878, October 15, 2014 - RESIDENTS OF LOWER ATAB & TEACHERS’ VILLAGE, STO.

TOMAS PROPER BARANGAY,


BAGUIO CITY, REPRESENTED BY BEATRICE T. PULAS, CRISTINA A. LAPPAO. MICHAEL MADIGUID, FLORENCIO MABUDYANG AND
FERNANDO DOSALIN, Petitioners, v. STA. MONICA INDUSTRIAL & DEVELOPMENT CORPORATION, Respondent.

SECOND DIVISION

G.R. No. 198878, October 15, 2014

RESIDENTS OF LOWER ATAB & TEACHERS’ VILLAGE, STO. TOMAS PROPER BARANGAY, BAGUIO CITY, REPRESENTED
BY BEATRICE T. PULAS, CRISTINA A. LAPPAO. MICHAEL MADIGUID, FLORENCIO MABUDYANG AND FERNANDO
DOSALIN, Petitioners, v. STA. MONICA INDUSTRIAL & DEVELOPMENT CORPORATION, Respondent.

DECISION

DEL CASTILLO, J.:

This Petition for Review on Certiorari1 seeks to set aside: 1) the August 5, 2011 Decision2 of the Court of Appeals (CA) in CA-G.R.
CV No. 84561 which affirmed the December 6, 2004 Decision 3 of the Regional Trial Court of Baguio City (Baguio RTC), Branch 6 in
Civil Case No. 4946-R; and 2) the CA’s October 3, 2011 Resolution 4 denying herein petitioners’ Motion for Reconsideration.5 cralawlaw lib rary

Factual Antecedents

In May 2001, petitioners – residents of Lower Atab & Teachers’ Village, Sto. Tomas Proper Barangay, Baguio City – filed a civil case
for quieting of title with damages against respondent Sta. Monica Industrial and Development Corporation. The case was docketed
as Civil Case No. 4946-R and assigned to Branch 59 of the Baguio RTC.6 The Complaint7 in said case essentially alleged that
petitioners are successors and transferees-in-interest of Torres, the supposed owner of an unregistered parcel of land in Baguio City
(the subject property, consisting of 177,778 square meters) which Torres possessed and declared for tax purposes in 1918; that
they are in possession of the subject property in the concept of owner, declared their respective lots and homes for tax purposes,
and paid the real estate taxes thereon; that in May 2000, respondent began to erect a fence on the subject property, claiming that
it is the owner of a large portion thereof8 by virtue of Transfer Certificate of Title No. T-631849 (TCT No. T-63184); that said TCT
No. T-63184 is null and void, as it was derived from Original Certificate of Title No. O-281 (OCT No. O-281), which was declared
void pursuant to Presidential Decree No. 127110 (PD 1271) and in the decided case of Republic v. Marcos;11 and that TCT No. T-
63184 is a cloud upon their title and interests and should therefore be cancelled. Petitioners thus prayed that respondent’s TCT No.
T-63184 be surrendered and cancelled; that actual, moral and exemplary damages, attorney’s fees, legal expenses, and costs be
awarded in their favor; and finally, that injunctive relief be issued against respondent to prevent it from selling the subject
property.

In its Answer with Special Affirmative Defenses and Counterclaim, 12 respondent claimed that petitioners have no cause of action;
that TCT No. T-63184 is a valid and subsisting title; that the case for quieting of title constitutes a collateral attack upon TCT No. T-
63184; and that petitioners have no title to the subject property and are mere illegal occupants thereof. Thus, it prayed for the
dismissal of Civil Case No. 4946-R and an award of exemplary damages, attorney’s fees, litigation expenses, and costs in its favor.

In their Pre-Trial Brief13 and Memorandum,14 petitioners acknowledged that while they declared their respective lots for tax
purposes, they applied for the purchase of the same – through Townsite Sales applications – with the Department of Environment
and Natural Resources (DENR).

Ruling of the Regional Trial Court

After trial, the Baguio RTC issued a Decision15 dated December 6, 2004, the dispositive portion of which reads: cha nRoblesvi rt ual Lawlib rary

WHEREFORE, Judgment is hereby rendered in favor of defendant Sta. Monica Industrial and Development Corporation and against
the plaintiffs, as follows:
chanRob lesvi rtua lLawl ibra ry

1. Dismissing the Complaint for Quieting of Title and Damages with Prayer for a Writ of Preliminary Injunction of plaintiffs;

2. Dismissing likewise the counterclaim for Damages and attorney’s fees of defendant corporation since it has not been shown that
the plaintiffs acted in bad faith in filing the Complaint. Without pronouncement as to costs.

SO ORDERED.16

The trial court held that Civil Case No. 4946-R constitutes a collateral attack upon respondent’s TCT No. T-63184, which became
indefeasible after one year from the entry of the decree of registration thereof. It held that if it is claimed that respondent’s title is
void, then a direct proceeding should have been filed by the State to annul it and to secure reversion of the land; petitioners have
no standing to do so through a quieting of title case. The trial court added that TCT No. T-63184 is a subsisting title; its validity
was confirmed through the annotation therein by the Baguio City Register of Deeds – Entry No. 184804-21-15917 – that TCT No. T-
27096, from which TCT No. T-63184 was derived, was validated by the PD 1271 Committee in a May 9, 1989 Resolution; that
petitioners could not present any title to the subject property upon which to base their case for quieting of title, and have failed to
show during trial that they have a cause of action against respondent.

Petitioners filed a Motion for Reconsideration,18 but the trial court denied the same in a January 17, 2004 Resolution. 19 c ralawlawl ibra ry

Ruling of the Court of Appeals

In an appeal to the CA which was docketed as CA-G.R. CV No. 84561, petitioners insisted that they have a cause of action against
respondent for quieting of title and damages; that Civil Case No. 4946-R is not a collateral attack upon respondent’s title; that Civil
Case No. 4946-R is not a case for reversion and annulment of title which could only be filed by the State; and that the trial court
erred in finding that respondent’s title was validated in accordance with law.

On August 5, 2011, the CA issued the assailed Decision affirming the trial court, thus: c hanRoble svirtual Lawlib ra ry

In this case, plaintiffs-appellants20 are without any title to be cleared of or to be quieted nor can they be regarded as having
equitable title over the subject property. Ballantine’s Law Dictionary defines an equitable title as follows: c hanro blesvi rt uallawli bra ry

“A title derived through a valid contract or relation, and based on recognized equitable principles; the right in the party, to whom it
belongs, to have the legal title transferred to him (15 Cyc. 1097; 16 Id. 90). In order that a plaintiff may draw to himself an
equitable title, he must show that the one from whom he derives his right had himself a right to transfer. x x x”

xxxx
In the instant case, plaintiffs-appellants cannot find refuge in the tax declarations and receipts under their names considering that
the same are not incontrovertible evidence of ownership.

Moreover, plaintiffs-appellants’ act of questioning the validity of the title of the defendant-appellee21 constitutes a collateral attack
and under Section 48 of P.D. 1529, “a certificate of title shall not be subject to collateral attack. x x x”

xxxx

Meantime, it is meet to point out that P.D. 1271 invoked by plaintiffs-appellants themselves, specifically provides under Section 6
(paragraph 2) thereof that “the Solicitor General shall institute such actions or suits as may be necessary to recover possession of
lands covered by all void titles not validated under this Decree.” Hence, the Office of the Solicitor General, being mandated by law,
must be the proper party to institute actions to recover lands covered by void titles under the said decree x x x.

xxxx

As regards the validation of TCT No. T-63184 x x x, no error was committed by the Court a quo in ruling that the same is in
accordance with law. It is important to note that the validation of the subject TCT was never disputed by the Register of Deeds or
any other government agency. Moreover, there is no showing that the TCT of the defendant-appellee and the OCT wherein it was
derived were declared null and void by virtue of Pres. Decree No. 1271. While the TCT of the defendant-appellee was issued under
L.R.C. Case No. 1, Record No. 211, it was validated in accordance with law in Entry No. 184804-21-159 annotated at the dorsal
side of the subject title.

xxxx

WHEREFORE, premises considered, the Decision dated December 6, 2004 of the Regional Trial Court, Branch 6, Baguio City is
AFFIRMED in toto.

SO ORDERED.22 c hanro bles law

Petitioners moved for reconsideration, but in its October 3, 2011 Resolution, the CA stood its ground. Hence, the instant Petition.

Issues

Petitioners raise the following issues in this Petition: cha nRoblesvi rt ualLaw lib rary

1. The Trial Court and the Court of Appeals erred in finding that the Petitioners x x x have no cause of action.

2. The Trial Court and the Court of Appeals erred in finding that the action is a collateral attack on the Torrens Title of respondent
Corporation.

3. The Trial Court and the Court of Appeals erred in finding that the present action is to annul the title of respondent Corporation
due to fraud, [thus] it should be the Solicitor General who should file the case for reversion.

4. The Trial Court and the Court of Appeals erred in finding that the validation of TCT No. T-63184 registered in the name of
respondent Corporation was in accordance with law.23

Petitioners’ Arguments
In their Petition and Reply,24 petitioners seek a reversal of the assailed CA dispositions and the nullification of respondent’s TCT No.
T-63184 so that said title shall not “hinder the approval of the Townsite Sales Application of the [p]etitioners by the [DENR]-
Cordillera Administrative Region and stop the harassment being done by the Corporation on the [p]etitioners x x x.” 25 They argue
that they have equitable title over the subject property, having possessed the same for many years and obtained the rights of their
predecessor Torres; that Civil Case No. 4946-R is not a collateral attack upon TCT No. T-63184, as said title is null and void by
virtue of PD 1271 and the ruling in Republic v. Marcos; that there is no need to file a reversion case since TCT No. T-63184 has
been effectively declared void, and respondent is not in possession of the subject property; and finally, that Entry No. 184804-21-
159 cannot have the effect of validating TCT No. T-63184, because PD 1271 itself states that only certificates of title issued on or
before July 31, 1973 are considered valid.26 Since OCT No. O-281 – the predecessor title of TCT No. T-63184 – was issued only on
January 28, 1977, it is thus null and void, and all other titles subsequently issued thereafter, including TCT No. T-63184, are invalid
as well.

Respondent’s Arguments

On the other hand, respondent’s Comment 27 simply reiterates the pronouncement of the CA. Consequently, it prays for the denial
of the instant Petition.

Our Ruling

The Court denies the Petition.

For an action to quiet title to prosper, two indispensable requisites must be present, 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.”28 cralawlawl ibra ry

“Legal title denotes registered ownership, while equitable title means beneficial ownership.” 29 cralaw lawlib rary

Beneficial ownership has been defined as ownership recognized by law and capable of being enforced in the courts at the suit of the
beneficial owner. Black’s Law Dictionary indicates that the term is used in two senses: first, to indicate the interest of a beneficiary
in trust property (also called “equitable ownership”); and second, to refer to the power of a corporate shareholder to buy or sell the
shares, though the shareholder is not registered in the corporation’s books as the owner. Usually, beneficial ownership is
distinguished from naked ownership, which is the enjoyment of all the benefits and privileges of ownership, as against possession of
the bare title to property.30
c hanro bles law

Petitioners do not have legal or equitable title to the subject property. Evidently, there are no certificates of title in their respective
names. And by their own admission in their pleadings, specifically in their pre-trial brief and memorandum before the trial court,
they acknowledged that they applied for the purchase of the property from the government, through townsite sales applications
coursed through the DENR. In their Petition before this Court, they particularly prayed that TCT No. T-63184 be nullified in order
that the said title would not hinder the approval of their townsite sales applications pending with the DENR. Thus, petitioners
admitted that they are not the owners of the subject property; the same constitutes state or government land which they would
like to acquire by purchase. It would have been different if they were directly claiming the property as their own as a result of
acquisitive prescription, which would then give them the requisite equitable title. By stating that they were in the process of
applying to purchase the subject property from the government, they admitted that they had no such equitable title, at the very
least, which should allow them to prosecute a case for quieting of title.

In short, petitioners recognize that legal and equitable title to the subject property lies in the State. Thus, as to them, quieting of
title is not an available remedy.

Lands within the Baguio Townsite Reservation are public land.31 Laws and decrees such as PD 1271 were passed recognizing
ownership acquired by individuals over portions of the Baguio Townsite Reservation, but evidently, those who do not fall with in the
coverage of said laws and decrees – the petitioners included – cannot claim ownership over property falling within the said
reservation. This explains why they have pending applications to purchase the portions of the subject property which they occupy;
they have no legal or equitable claim to the same, unless ownership by acquisitive prescription is specifically authorized with
respect to such lands, in which case they may prove their adverse possession, if so. As far as this case is concerned, the extent of
petitioners’ possession has not been sufficiently shown, and by their application to purchase the subject property, it appears that
they are not claiming the same through acquisitive prescription.

The trial and appellate courts are correct in dismissing Civil Case No. 4946-R; however, they failed to appreciate petitioners’
admission of lack of equitable title which denies them the standing to institute a case for quieting of title. Nevertheless, they are
not precluded from filing another case – a direct proceeding to question respondent’s TCT No. T-63184; after all, it appears that
their townsite sales applications are still pending and have not been summarily dismissed by the government – which could indicate
that the subject property is still available for distribution to qualified beneficiaries. If TCT No. T-63184 is indeed null and void, then
such proceeding would only be proper to nullify the same. It is just that a quieting of title case is not an option for petitioners,
because in order to maintain such action, it is primarily required that the plaintiff must have legal or equitable title to the subject
property – a condition which they could not satisfy.

With the conclusion arrived at, the Court finds no need to resolve the other issues raised.

WHEREFORE, the Petition is DENIED. The assailed August 5, 2011 Decision and October 3, 2011 Resolution of the Court of
Appeals in CA-G.R. CV No. 84561 are AFFIRMED.

SO ORDERED.
G.R. No. 180076 November 21, 2012

DIONISIO MANANQUIL, LAUDENCIA MANANQUIL-VILLAMOR, ESTANISLAO MANANQUIL, and DIANITA


MANANQUIL-RABINO, represented by OTILLO RABINO, Petitioners,
vs.
ROBERTO MOICO, Respondent.**

DECISION

DEL CASTILLO, J.:

In order that an action for quieting of title may proper, it is essential that the plaintiff must have legal or equitable title
to, or interest in, the property which is the subject-matter of the action. Legal title denotes registered ownership, while
equitable title means beneficial ownership. In the absence of such legal or equitable title, or interest, there is no cloud
to be prevented or removed.

This Petition for Review on Certiorari1 assails the March 13, 2007 Decision2 of the Court of Appeals (CA) in CA-G.R.
CV No. 81229, which reversed and set aside the January 2, 2001 Decision 3 of the Malabon Regional Trial Court,
Branch 74 in Civil Case No. 2741-MN, thus dismissing the said civil case for quieting of title.

Factual Antecedents

Lots 18 and 19 in Dagat-Dagatan, Navotas form part of the land previously expropriated by the National Housing
Authority (NHA) and placed under its Tondo Dagat-Dagatan Foreshore Development Project – where occupants,
applicants or beneficiaries may purchase lots on installment basis. In October 1984, Lot 18 was awarded to spouses
Iluminardo and Prescilla Mananquil under a Conditional Contract to Sell. Lot 19, on the other hand, was sold to
Prescilla in February 1980 by its occupant.

In 1991, Iluminardo and Prescilla died without issue, but it turned out that Prescilla had a child by a previous marriage
– namely Eulogio Francisco Maypa (Eulogio). After the spouses’ death, Iluminardo’s 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, Eulogio Baltazar Maypa and
Brenda Luminugue, 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).

In May 1997, Moico began evicting the Mananquils’ tenants and demolishing the structures they built on Lots 18 and
19. In June, the Mananquils instituted Civil Case No. 2741-MN for quieting of title and injunctive relief.

Ruling of the Regional Trial Court

The trial court issued a temporary restraining order, thus suspending eviction and demolition. After trial on the merits,
a Decision was rendered in favor of the Mananquils. The dispositive portion thereof reads:

WHEREFORE, premises considered, judgment is hereby rendered:

1. Ordering that a permanent injunction be issued enjoining defendant Roberto Moico to refrain from
threatening the tenants and destroying the improvements standing on the subject properties and from filing
the ejectment suits against the tenants;

2. Ordering the Extrajudicial Settlement of Estate with Waiver of Rights and Sale and the Deed of Absolute
Sale dated January 9, 1997 cancelled for having no force and effect;
3. Declaring plaintiffs to be rightfully entitled to the subject properties and the Extrajudicial Settlement of
Heirs of the plaintiffs to be valid and enforceable;

4. Ordering defendants to pay jointly and severally the plaintiffs the following, to wit:

a. P50,000.00 as moral damages;

b. P50,000.00 as exemplary damages;

c. P50,000.00 for and as attorney’s fees; and

d. Costs of suit.

SO ORDERED.4

Ruling of the Court of Appeals

Moico appealed to the CA, which reversed the trial court. It held that the petitioners have failed to show that
Iluminardo and Prescilla have –

x x x perfected their grant/award from the NHA so as to secure a firm, perfect and confirmed title over the subject lots.
It must be stressed that the Conditional Contract to Sell that covers Lot No. 18 stipulates several terms and
conditions before a grantee of the NHA may legally acquire perfect title over the land, and there should be no mistake
that the same stipulations hold true with respect to Lot No. 19. Inter alia, the more vital contractual conditions, are: (a)
payment in installment of the price for a specified period, (b) personal use of and benefit to the land by the grantee,
and (c) explicit prohibition from selling, assigning, encumbering, mortgaging, leasing, or sub-leasing the property
awarded x x x.5

The CA noted that Lots 18 and 19 must still belong to the NHA, in the absence of proof that Iluminardo and Prescilla
have completed installment payments thereon, or were awarded titles to the lots. And if the couple disposed of these
lots even before title could be issued in their name, then they may have been guilty of violating conditions of the
government grant, thus disqualifying them from the NHA program. Consequently, there is no right in respect to these
properties that the Mananquils may succeed to. If this is the case, then no suit for quieting of title could prosper, for
lack of legal or equitable title to or interest in Lots 18 and 19.

Issues

The present recourse thus raises the following issues for the Court’s resolution:

THE COURT OF APPEALS GRAVELY ERRED IN PASSING UPON AN ISSUE NOT BEING ASSIGNED
AS ERROR IN THE APPELLANTS’ BRIEF OF PRIVATE RESPONDENTS AND NOT TOUCHED UPON
DURING THE TRIAL IN THE COURT A QUO PARTICULARLY THE ALLEGED VIOLATION OF THE
SPOUSES ILUMINARDO AND PRESCILLA MANANQUIL OF THE CONDITIONAL CONTRACT TO SELL
PURPORTEDLY COVERING THE PROPERTIES IN QUESTION, TO SUIT ITS RATIONALIZATION IN ITS
QUESTIONED DECISION JUSTIFYING THE REVERSAL OF THE DECISION OF THE COURT A QUO.

II

THE COURT OF APPEALS ALSO COMMITTED A GRIEVOUS ERROR IN CONSTRUING THE


PROVISIONS OF ARTICLES 476 AND 477 OF THE CIVIL CODE AGAINST PETITIONERS
NOTWITHSTANDING THE POSITIVE CIRCUMSTANCES OBTAINING IN THIS CASE POINTING TO THE
PROPRIETY OF THE CAUSE OF ACTION FOR QUIETING OF TITLE.6

Petitioners’ Arguments
Petitioners argue that the CA cannot touch upon matters not raised as issues in the trial court, stressing that the NHA
did not even intervene during the proceedings below to ventilate issues relating to the rights of the parties to Lots 18
and 19 under the Tondo Dagat-Dagatan Foreshore Development Project. Petitioners claim that since the issue of
violation of the terms of the grant may be resolved in a separate forum between the Mananquils and the NHA, it was
improper for the CA to have pre-empted the issue.

On quieting of title, petitioners advance the view 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 pursue Civil
Case No. 2741-MN; whatever rights Iluminardo had over the lots were transmitted to them from the moment of his
death, per Article 777 of the Civil Code. And among these rights are the rights to continue with the amortizations
covering Lots 18 and 19, as well as to use and occupy the same; their interest as successors-in-interest, though
imperfect, is enough to warrant the filing of a case for quieting of title to protect these rights.

Respondent Moico’s Arguments

Moico, on the other hand, argues that because the issue relating to Iluminardo and Prescilla’s possible violation of the
terms and conditions of the NHA grant is closely related to the issue of ownership and possession over Lots 18 and
19, then the CA possessed jurisdiction to pass upon it.

Moico supports the CA view that petitioners failed to prove their title or interest in the subject properties, just as he
has proved below that it was his predecessor, Eulogio, who paid all obligations relative to Lots 18 and 19 due and
owing to the NHA, for which reason the NHA released and cleared the lots and thus paved the way for their proper
transfer to him.

Our Ruling

The petition lacks merit.

An action for quieting of title is essentially a common law remedy grounded on equity. The competent court is tasked
1âwphi 1

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.

Proof of heirship alone does not suffice; the Mananquils must prove to the satisfaction of the courts that they have a
right to succeed Iluminardo under the law or terms of the NHA project, and are not disqualified by non-payment,
prohibition, lack of qualifications, or otherwise.

WHEREFORE, premises considered, the Petition is DENIED for lack of merit. The March 13, 2007 Decision of the
Court of Appeals in CA-G.R. CV No. 81229 is AFFIRMED.

SO ORDERED.