Green Acres Holdings,

Inc. v. Cabral

G.R. Nos. 175542 &

183205
 • Victoria Cabral owned a parcel of land covered by a
Transfer Certificate of Title under the coverage of PD
No. 27. To the detriment of Cabral, Spouses Morada
were later issued three Emancipation Patents, one of
which they converted to Transfer Certificate of Title.

FACTS •Alleging that the Emancipation Patents issued to

the spouses Moraga were obtained through fraud,
Cabral filed a complaint before the Provincial
Agrarian Reform Adjudicator (PARAD) seeking for
the cancellation of such Emancipation Patents. The
complaint being dismissed due to lack of merit,
Cabral appealed to the Department of Agrarian
Reform Adjudication Board (DARAB).
 •While the appeal was pending, spouses Morada
subdivided into three smaller lots the one which was
under TCT. These lots were later on sold to Filcon
Ready Mixed, Inc. and was later on purchased by
Green Acres Holdings, Inc.

FACTS •Thereafter, titles of Filcon were cancelled and new

titles in the name of Green Acres were issued by the
Register of Deeds. Confident enough, Green Acres
constructed a warehouse and building complex on
the same.
 • Not so long after, the judgment of DARAB in favor
of Cabral was rendered, ordering the cancellation of
the titles issued in the names of spouses Moraga and
Filcon for having been illegally acquired, and thus
FACTS vacate the premises of the lands in question.

• Furthermore, DARAB directed the Register of

Deeds to restore TCT in the name of Victoria
Cabral.
 •For its security and protection, Green Acres filed a
Complaint for quieting of Title, Damages with
FACTS Preliminary Injunction and Writ of Preliminary
Attachment before a Regional Trial Court, against
Cabral, Spouses Morada, Filcon, the DARAB, and the
Registry of Deeds.
 •Cabral filed a Demurrer of Evidence arguing that
Green Acres failed to prove that it was a purchaser in
good faith and for value; that the complaint is not
appropriate for quieting of title since it omitted to
assail her titles over subject property; and that the
FACTS trial court has no jurisdiction over the subject
property.

•The trial court granted the demurrer and dismissed

the case.
 Green Acres filed an appeal to which the CA denied.

•CA held that the only issue in an action to quiet title is

whether there is a cloud in a title to a real property by
reason of any instrument, record, claim, encumbrance or a
proceeding which is apparently valid or effective and
FACTS according to the CA the DARAB decision does not fall
within this enumeration.

•The case was elevated to the Supreme Court, seeking for

the reversal of the CA’s decisions adverse to them
 •Whether the said DARAB decision issued in favor
of Cabral constitutes a cloud on Green Acres title

ISSUE over the subject properties. (YES)

20XX presentation title 8

 •DARAB decision in favor of Cabral constitutes a cloud
on Green Acres’ title over the subject properties.

Article 476 of the Civil Code provides:

•“Whenever there is a cloud on title to real property or

any interest therein, by reason of any instrument,
RULING record, claim, encumbrance or proceeding which is
apparently valid or effective but is in truth and in fact
invalid, ineffective, voidable, or unenforceable, and may
be prejudicial to said title, an action may be brought to
remove such cloud or to quiet the title. An action may
also be brought to prevent a cloud from being cast upon
title to real property or any interest therein.”
 As Green Acres correctly points out, the DARAB
decision, is both an "instrument" and a "record.”

Black’s Law Dictionary defines the following:

•An “instrument” as a document or writing which gives

formal expression to a legal act or agreement, for the
RULING purpose of creating, securing, modifying or terminating a
right.

•A “record”, is defined as a written account of some act,

court proceeding, transaction or instrument drawn up
under authority of law, by a proper officer, and designed
to remain as a memorial or permanent evidence of the
matters to which it relates.
 •It is likewise a "claim" which is defined as a cause of
action or a demand for money or property since
Cabral is asserting her right over the subject lots.

•More importantly, it is a "proceeding" which is

RULING defined as a regular and orderly progress in form of
law including all possible steps in an action from its
commencement to the execution of judgment and
may refer not only to a complete remedy but also to a
mere procedural step that is part of a larger action or
special proceeding.
 Quieting of title is a common law remedy for the removal
of any cloud upon, doubt, or uncertainty affecting title to
real property.

For an action to quiet title to prosper, two indispensable

requisites must concur:

(1) the plaintiff or complainant has a legal or equitable title

RULING or interest in the real property subject of the action; and

(2) the deed, claim, encumbrance, or proceeding claimed

to be casting a 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 requisites to quiet a title were met by Green Acres.

 The petition of Green Acres was GRANTED and

RULING the titles of subject property in dispute in the

name of Green Acres were made VALID and any
cloud over such titles were REMOVED.
THANK YOU! Samuel Edrian Abad
Presented by: Arvy L. Agustin