The Supreme Court has denied the Petition for Review on Certiorari filed by Alfaro and spouses Uy, ruling that they are not the real parties-in-interest in a case seeking to annul the title of a parcel of land registered in the name of spouses Aguila. The Court affirmed the April 24, 2025 and December 4, 2025 Resolutions of the Court of Appeals in CA-G.R. SP No. 188245.
The Case
Alfaro et al. lodged a complaint for annulment of title with recovery of damages against spouses Aguila and the Registry of Deeds of Isabela before the MTCC of Cauayan City, Isabela.
Alfaro et al. averred that the land they respectively owned is situated in Barrio Nungnungan, Municipality of Cauayan City, Isabela and was formerly covered by Transfer Certificate of Title (TCT) No. EP-019130, registered in the name of Ricardo Mauricio. The parcel was subdivided into two lots, Lots 10-A and 10-B, with an area of 15,000 square meters each. Spouses Uy and Alfaro acquired Lots 10-A and 10-B and became registered owners under TCT No. T-336807 and TCT No. 035-2016002170, respectively.
On May 19, 1998, Alfaro erected a building over Lot 10-B, along the provincial road. In January 2016, spouses Aguila filed a complaint for recovery of possession against spouses Edna and Renato Alfaro, asserting that the building encroached on Lot 11, registered in their name under TCT No. 035-2014004922 with an area of 517 square meters. Spouses Aguila averred that their title derived from TCT No. T-392254 in the name of Spouses Ma. Theresa Uy and Ronald Uy, which cancelled TCT No. T-392118 in the name of Ricardo Mauricio, which in turn cancelled TCT No. EP-019130.
Alfaro et al. claimed the documents were spurious and prayed that they be nullified and spouses Aguila be ordered to pay moral damages, attorney's fees and costs. Spouses Aguila maintained the complaint was filed by persons who are not real parties-in-interest, that their title had become indefeasible, and that they were innocent purchasers for value.
The MTCC declared the documents null and void and ordered spouses Aguila to pay Alfaro et al. PHP 30,000.00 as attorney's fees and costs of suit. On appeal, the RTC reversed and set aside the MTCC Decision, dismissing the complaint for lack of standing and legal basis. Alfaro et al. turned to the Court of Appeals, which denied their Motion for Extension of Time to File Petition for Review, citing their counsel's heavy workload, and later denied their motion for reconsideration.
The Issue
The Court addressed whether the CA erred in denying the motion for extension of time to file the Petition for Review, and whether Alfaro et al. are real parties-in-interest entitled to seek the annulment of the title covering Lot 11.
The Ruling
The Court held that the Petition must necessarily fail. It ruled that the grant of a motion for extension of time is discretionary on the part of the CA, and found it within the CA's discretionary power to pronounce that "heavy workload" is not a compelling reason to extend the reglementary period set forth by law.
The dispositive portion reads: "ACCORDINGLY, the Petition for Review on Certiorari is DENIED. The April 24, 2025 and December 4, 2025 Resolutions of the Court of Appeals in CA-G.R. SP No. 188245, are AFFIRMED."
The Court also ordered that a copy of the Decision be furnished to the Department of Agrarian Reform and the Land Registration Authority for appropriate action.
By the Numbers
- Lots 10-A and 10-B: 15,000 square meters each
- Lot 11: 517 square meters
- TCT No. EP-019130, registered in the name of Ricardo Mauricio
- TCT No. 035-2014004922, in the name of spouses Aguila
- PHP 30,000.00 ordered by the MTCC as attorney's fees and costs
- May 19, 1998 — Alfaro erected a building over Lot 10-B
- January 2016 — spouses Aguila filed complaint for recovery of possession
- May 15, 2014 — Department of Agrarian Reform certification
- September 21, 2022 — MTCC Decision; November 18, 2024 — RTC Decision
- April 24, 2025 and December 4, 2025 — CA Resolutions
The Court's Reasoning
The Court found the petition devoid of merit. It affirmed that the RTC properly ruled that Alfaro et al. are not the real parties-in-interest. The mere fact that Alfaro et al. are owners of the land adjacent to Lot 11 does not give them the right to ask for the annulment of the title covering that realty registered in the names of spouses Aguila. The Court explained that while they may have an interest over the land in question, such is a mere incidental interest and not the material interest contemplated under the law.
The Court noted that under Rule 42, Section 1 of the Rules of Court, the grant of a motion for extension of time is discretionary, and heavy workload standing alone is hardly a compelling or meritorious reason to allow extensions of time to file pleadings.
As a final word, the Court observed that in view of the Department of Agrarian Reform certification that TCT No. EP-019130 was issued for Lot 10, while no emancipation patent has yet been issued for Lot 11, there appears to be a valid issue anent the chain of titles of spouses Aguila's certificate of title. For this reason, notwithstanding the dismissal of the complaint, the Court deemed it proper to furnish copies of the Decision to the Department of Agrarian Reform and the Land Registration Authority.
Source: Supreme Court Decision, G.R. No. E-05073.
This report summarizes a public Supreme Court decision and is not legal advice.