G.R. No. 243146 . September 09, 2020.
MR. AMOR VELASCO, ET AL., PETITIONERS, VS. REBECCA MAGPALE, REPRESENTED BY PILIPINAS MAGPALE-UY, RESPONDENT.

FACTS

Respondent Rebecca Magpale is the registered owner of a 6,595-square-meter parcel of land in San Jose City, Nueva Ecija, covered by TCT No. 15102. The property originated from a larger tract, Lot 3360-A-2, covered by TCT No. NT-31597 (11472) and owned pro indiviso by several co-owners, including Francisco Velasco. On April 9, 1992, the co-owners, including Francisco and respondent, executed an Extrajudicial Partition with Subdivision Agreement, subdividing the original property. Lot 3360-A-2-C was allotted to a group including respondent and was further subdivided. Respondent acquired her specific 6,595-square-meter portion through a waiver of rights from her siblings. Petitioners, who are the heirs of Francisco Velasco and their tenants, built houses on respondent’s titled portion, claiming ownership through their predecessor, Francisco.

ISSUE

Whether petitioners, as heirs of a co-owner of the original property, have a superior right of possession over the specific portion already titled in the name of respondent pursuant to a valid extrajudicial partition.

RULING

No. The Supreme Court affirmed the rulings of the lower courts ordering petitioners to vacate and remove their structures. The legal logic is anchored on the principle that a Torrens title is conclusive evidence of ownership. Respondent’s TCT No. 15102 was issued as a direct result of the April 9, 1992 Extrajudicial Partition, which was duly annotated on the mother title. This partition, executed by all co-owners including Francisco Velasco, was valid and binding. It effectively dissolved the co-ownership and designated specific, exclusive portions to the individual parties. Consequently, Francisco’s undivided interest in the original property was extinguished and converted into an exclusive right over the specific lot allotted to his group (Lot 3360-A-2-B), not over respondent’s separately titled parcel. Petitioners, as Francisco’s heirs, merely stepped into his shoes and thus have no claim to respondent’s adjudicated property. Their possession, being without right, is unlawful. The Court emphasized that a certificate of title, once issued, cannot be collaterally attacked. Any claim of irregularity in the partition process must be pursued in a direct proceeding, not through a defense in an ejectment or accion publiciana case. The proper remedy for petitioners, if they believe the partition was fraudulent or that Francisco was deprived of his lawful share, is to file a separate action for reconveyance or annulment of title, not to withhold possession from the registered owner.