Caldito v.

Obando
G.R. No. 181596, Jan. 30, 2017

Facts:
 
 The case is about a complaint of quieting of ownership over a parcel of land filed by Spouses
Caldito against respondents Obando.
 Spouses Ballesteros sold the subject parcel of land to the Spouses Caldito. Spouses Caldito
then attempted to build a house on the subject parcel of land but the respondents Obandos
prevented them from completing the construction.
 The Obandos argued that the Spouses Ballesteros were not the owners and possessors of the
subject parcel of land, because the said lot was inherited by their father, Paterno, from its
original owner Felipe, they have been paying the real property taxes for the entire property.
 They asserted that the Spouses Caldito are buyers in bad faith since their family had been in
possession of the entire Lot and had been in an open, peaceful, and uninterrupted possession
of the whole property up to the present or for more than 30 years in the concept of an owner.

Issue(s):
 
1. Were the Spouses Caldito able to prove ownership over the subject parcel of land?

Ruling(s):
 
1. No. It is clear that the Spouses Calditos cause of action must fail because they were not able
to prove equitable title of ownership over the subject parcel of land. Although the Spouses
Calditos submitted official receipts and tax declarations to prove payment of taxes, nowhere in
the evidence was it shown that Spouses Ballesteros (sellers) declared the subject parcel of
land in their name for taxation purposes or paid taxes due. What the Calditos’ presented as
their pieces of evidence are receipts and tax declarations which they have paid as new
owners. But they could not rely on these tax declarations and receipts because those are too
recent and do not reflect the fact that their predecessors-in-interest paid taxes for the land.

Meanwhile, the Obandos’ presentation of the tax declarations and tax receipts which all are of
ancient era indicate possession in the concept of an owner by the respondents and their
predecessors-in-interests. Thus, from the time of the filing of the quieting of title by the
Spouses Calditos in 2003, the Obandos’ have been in possession of the entire Lot in the
concept of an owner for almost 42 years. This period of time is sufficient to vest extraordinary
acquisitive prescription over the property on the respondents. It is immaterial now whether the
respondents possessed the property in good faith or not.

Notes:
The cause of action relating to an action to quiet title which has 2 indispensable requisites, namely:
1. The plaintiff or complainant has a legal or an equitable title to or interest in the real property
subject of the action (Calditos’ failed to prove this);
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
The tax declarations in the name of Paterno take on great significance because the Obandos’ can
track their claim of ownership to that of their father. It is worthy to note that the Obandos' father
Paterno (to whom they inherited the entire Lot) paid the taxes due under his name and subsequently,
the Obandos’ paid the taxes due after the death of Paterno. Granting without admitting that Felipe's
possession of Lot cannot be tacked with the Obandos’ possession, the latter's possession can be
tacked with that of Paterno.