GR 128750; (January, 2001) (Digest)
G.R. No. 128750, January 18, 2001
CARQUELO OMANDAM and ROSITO ITOM, petitioners, vs. COURT OF APPEALS, BLAS TRABASAS and AMPARO BONILLA, respondents.
FACTS
The case involves a dispute over a parcel of land covered by Homestead Patent No. IX-6-40 and Original Certificate of Title (OCT) No. P-22-690 issued to Camilo Lasola. Respondent Blas Trabasas initially purchased the land from Dolores Sayson in 1983. Upon discovering petitioners Carquelo Omandam and Rosito Itom in possession, Trabasas, upon Sayson’s advice, repurchased the land directly from the registered owner, Lasola, in 1987 and subsequently obtained a Transfer Certificate of Title. In 1990, respondents filed a complaint for recovery of possession against petitioners, who claimed ownership based on a purchase from a certain Godofredo Sela, alleging prior possession. The Regional Trial Court ruled in favor of petitioners, declaring they had equitable possession rights and ordering reconveyance.
ISSUE
The core issue is whether the Court of Appeals erred in reversing the trial court and upholding the registered title of the respondents, thereby ordering the petitioners to vacate the land.
RULING
The Supreme Court denied the petition and affirmed the Court of Appeals. The Court held that petitioners’ arguments largely involved questions of fact, which are not reviewable in a petition for review under Rule 45. The factual findings of the Court of Appeals are conclusive, especially as petitioners failed to demonstrate any recognized exception to this rule. More critically, the Court emphasized the finality of the administrative decision from the Department of Environment and Natural Resources (DENR), which had dismissed Omandam’s protest for failure to prove fraud in the issuance of Lasola’s homestead patent. This administrative order, having attained finality, conclusively established the validity of the original title. Consequently, respondents, as successors-in-interest to the registered owner Lasola, possess a superior right to the property based on their indefeasible Torrens title. The petitioners’ claim, being a collateral attack on a title that had long become incontrovertible, could not prevail. The action for reconveyance, implied in their protest and counterclaim, was also deemed to have prescribed. Thus, the Court of Appeals correctly ordered the petitioners to vacate and surrender the land to the registered owners.