CERTIFICATE OF TITLE AS AN ABSOLUTE AND INDEFEASIBLE EVIDENCE OF OWNERSHIP

HERE is a case (Alcantara v. Belen, G.R. No. 200204, April 25, 2017)  of quieting of title and reconveyance of possession.

The petitioners claimed that they were the registered owners of Lot No. 16932 - a 3,887-square-meter parcel of land and covered by Transfer Certificate of Title (TCT) No. T-36252.

The respondents, on the other hand, presented a sales agreement called Kasulatan ng Bilihang Tuluyan ng Lupa, alleging that they bought the property from its prior owners. They supported their claim of ownership with various Tax Declarations under the name of their predecessors-in-interest. They likewise submitted a Sketch/Special Plan of Lot No. 16932 prepared by a geodetic engineer .

The RTC ruled in favor of the petitioners. The lower court gave more weight to the certificate of title and Tax Declarations presented by petitioners, declaring them the absolute owners of Lot No. 16932. The trial court further dislodged the use of the Tax Declarations registered under the names of the respondents and their predecessors-in-interest, because these documents did not have the technical description of the land and its boundaries; and in contrast, the TCT of the prtitioners defined the subject property by metes and bounds, with a technical description approved by the Land Management Bureau.

However, the said decision was reversed on appeal before the Court of Appeals. The CA declared that Asuncion Alimon, mother of petitioner, Elvira Alcantara was not a possessor or cultivator of the subject land, a fact that voided the Free Patent issued to her, as well as the resulting OCT and TCT. The CA likewise ruled that petitioner, Elvira Alcantara was not a legal heir of Asuncion Alimon. The failure of the petitioners to show their legal entitlement to Lot No. 16932, the CA went on to declare respondents the owners of that property. It further ordered the cancellation of OCT No. P-512 and TCT No. T-36252.

ISSUE

Whether or not the CA committed errors of law in concluding the legal issue of ownership in favor of respondents on the basis of their Tax Declarations and the Kasulatan ng Bilihang Tuluyan ng Lupa notwithstanding the TCT of the petitioners. In short, whether or not a certificate of title may be sufficiently defeated by tax declarations and deeds of sale.

THE RULING OF THE SUPREME COURT

Based on established jurisprudence, the Supreme Court reiterated its ruling that the certificate of title is an absolute and indefeasible evidence of property ownership.

“As against an array of proofs consisting of tax declarations and/or tax receipts which are not conclusive evidence of ownership nor proof of the area covered therein, an original certificate of title indicates true and legal ownership by the registered owners over the disputed premises. Petitioners' OCT No. P-19093 should be accorded greater weight as against the tax declarations x x x offered by private respondents in support of their claim x x x.”

In Pioneer Insurance and Surety Corp. v. Heirs of Coronado (August 4, 2009),  the Supreme Court likewise had the occasion to emphasize that a certificate of title serves as evidence of an indefeasible and incontrovertible title to the property in favor of the person whose name appears therein. The real purpose of the Torrens System of land registration is to quiet title to land and put stop forever to any question as to the legality of the title.

According to the Supreme Court, the CA failed to cite any specific exhibit on record showing that the Asuncion Alimon (mother of the petitioner) did not possess the land when she applied for the patent. Hence, it jumped to conclusions without any sufficient basis for its premise. This form of adjudication is flawed. No less than the Constitution mandates that a court decision must express clearly and distinctly the facts and the law on which it is based.

As regards the status of petitioner, Elvira Alcantara, the Supreme Court, in Bagayas v. Bagayas (September 18, 2013), the Supreme Court reiterated that courts must refrain from making a declaration of heirship in an ordinary civil action because "matters relating to the rights of filiation and heirship must be ventilated in a special proceeding instituted precisely for the purpose of determining such rights." Straightforwardly, the CA is precluded from determining the issue of filiation in a proceeding for the quieting of title and accion reivindicatoria.

Said the Supreme Court, “The CA committed an error of law in giving precedence to the Tax Declarations and irrelevant deed of sale of Spouses Belen over a Torrens title to Lot No. 16932 registered to Spouses Alcantara. The appellate court likewise erred in nullifying the title of petitioners over the realty, because it did not provide any basis for invalidating the Free Patent of Asuncion Alimon. Finally, we find fault on the part of the CA in improperly declaring Elvira Alcantara an adopted child outside the confines of a special proceeding.”

PETITION GRANTED.

References:

Alcantara v. Belen, G.R. No. 200204, April 25, 2017

Spouses Ocampo v. Heirs of Dionisio, October 1, 2014

Pioneer Insurance and Surety Corp. v. Heirs of Coronado, August 4, 2009 

Vda. de Villanueva v. Court of Appeals, February 1, 2001.

Cureg v. Intermediate Appellate Court, September 7, 1989, citing Ferrer-Lopez v. Court of Appeals, May 29, 1987.