Case Digest – Clado-Reyes v.
Limpe (557 SCRA 400) WHETHER THE PETITIONERS HAVE A CAUSE
Facts:
The case is an action for quieting of title and
reconveyance. Based on the claim of Nino Reyes that he
through his predecessors-in-interest were in continuous
occupation of the subject property since 1945 and that they
were tenant farmers of the same land. They also claimed
that the said property was transferred to them by the
former owner Felipe Garcia through a verbal agreement
and that the same was also evidenced by the Certification
issued in 1979 and the Pagpapatunay issued by Simeon
Garcia the eldest son of Felipe Garcia. They also alleged
that every time Julius Limpe would visit the property he
would say that he would bring the title upon his return.
Reyes was however astonished by the letter which they
received from Limpe asserting the latter’s ownership over
the property.
In their answer Limpe alleges that they were the
legal owners of the property as evidenced by the Deed of
Exchange of Real Estate and Deed of Absolute sale
between them and Farm-Tech Industries. To further
bolster their claim Limpe also presented TCT No. T-
199627, Tax Declaration Nos. 1517212 and 952913 and
realty tax receipts14 of the lot, which were all registered
and declared in their names.
Because of the evidences presented the RTC and the
CA both decided in favour of Limpe which led us to the
present case.
Issue:
OF ACTION TO QUIET TITLE, RECONVEYANCE AND
DAMAGES AGAINST RESPONDENTS ?
Ruling:
No, an action for quieting of title originated in
equity jurisprudence to secure an adjudication that a claim
of title to or an interest in property, adverse to that of the
complainant, is invalid, so that the complainant and those
claiming under him may be forever free from any danger
of hostile claim. With that being said there are two
indispensable requisites in order that an action to quiet
title could prosper: (1) that the plaintiff or complainant has
a legal or an equitable title to or interest in the real
property subject of the action; and (2) that 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. It must however be noted that the
petitioners failed to satisfy the requisites provided above
considering that they merely cited Section 4 of Article XIII
of the 1987 Constitution and Section 2 of the
Comprehensive Agrarian Reform Law and claimed that
their title originated from it as evidenced by the
Certification and Pagpapatunay. They also failed to
provide any positive evidence that shows (1) that their
predecessor had legal title, i.e., a certificate of land
transfer; (2) that the lot was an agricultural lot and not a
commercial one as contended by respondents; and (3) that
they are qualified beneficiaries under the Agrarian Reform
Law. In the absence of the foregoing the claims of the
petitioners remains as allegations which is not supported
by evidence. Leading to the court givng more credence to
the claims of the respondent who was able to present
evidence to support their claims. For the respondents
presented evidence which clearly preponderates in their
favor. First, the transfer certificate of title, tax declarations
and realty tax receipts were all in their names. Second,
pursuant to the Torrens System, TCT No. RT-32498 (T-
199627) enjoys the conclusive presumption of validity and
is the best proof of ownership of the lot. Third, although
tax declarations or realty tax receipts are not conclusive
evidence of ownership, nevertheless, they are good indicia
of possession in the concept of an owner, for no one in his
right mind would be paying taxes for a property that is not
in his actual or at least constructive possession. As was
previously held, such realty tax payments constitute proof
that the holder has a claim of title over the property.

WHEREFORE, the instant petition is DENIED for

utter lack of merit. The Decision dated February 20, 2004
and the Resolution dated June 9, 2004, of the Court of
Appeals in CA-G.R. CV No. 70170 are AFFIRMED.