PABLITO MENESES and LORENZO MENESES, vs. THE HONORABLE COURT OF APPEALS, EDUARDO QUISUMBING, NORBERTO QUISUMBING, HEIRS OF EMILIO QUISUMBING (Carlos, Manuel and Paz, all surnamed Quisumbing), HEIRS OF FERNANDO QUISUMBING (Perla, Josefina, Napoleon, Honorato, Remedios and Alfonso, all surnamed…
- G.R. Number: G.R. No. 82220
- Promulgated: 1995-07-14
- Ponente: Quiason, J.
Doctrine
Fraud in the procurement of titles defeats the protection of indefeasibility and state-granted title cannot prevail when shown to have been obtained by fraud.
An appellate court may not radically reduce damages awarded by the trial court on mere humanitarian grounds; reduction must meet reasonableness and non-arbitrariness tests.
A public officer is personally liable for damages for acts done in bad faith and outside the scope of authority; immunity does not protect such conduct.
Facts
This petition seeks review of the Court of Appeals' 31 August 1987 decision affirming the RTC, Branch 37, Calamba, Laguna, which declared null and void original certificates of title and free patents issued to Pablito Meneses for lots found to be accretion lands belonging to Ciriaca Arguelles Vda. de Quisumbing.
The trial court declared Meneses' OCsT/Free Patents (Lot Nos. 1585 and 190) as accretion lands forming part of a larger accretion land adjudicated in LRC Case No. B-327, and ordered cancellation entries in the Register of Deeds.
Petitioners argued the land was part of the Laguna de Bay bed (citing a prior ruling) and invoked indefeasibility because the one-year period to impugn title had elapsed and titles were state grants.
The Court found fraud in the issuance of Meneses' free patents and titles, referencing this Court's prior decision in a prior ruling holding petitioners liable under the Anti-Graft and Corrupt Practices Act.
Issues
Whether the lands covered by Meneses' certificates of title/free patents are accretion lands belonging to the Quisumbings.
Whether the principle of indefeasibility of title protects petitioners given the lapse of the statutory period to impugn title and because their titles were state grants.
Whether the Court of Appeals properly reduced the trial court's award of damages to the Quisumbing family.
Ruling
The petition in G.R. No. 82220 is DENIED; the Court AFFIRMED the Court of Appeals' decision declaring Meneses' titles null and void as accretion lands and ordering cancellation entries in the Registry of Deeds.
The petition in G.R. No. 83059 is GRANTED: the Court SET ASIDE the Court of Appeals' reduction of damages and restored the trial court's award; costs were imposed on petitioners in G.R. No. 82220 and respondent Braulio Darum.