GR 133465; (September, 2000) (Digest)
G.R. No. 133465; September 25, 2000
AMELITA DOLFO, petitioner, vs. THE REGISTER OF DEEDS FOR THE PROVINCE OF CAVITE, TRECE MARTIRES CITY, THE REPUBLIC OF THE PHILIPPINES, LAND REGISTRATION AUTHORITY, CESAR E. CASAL, et al., respondents.
FACTS
Petitioner Amelita Dolfo, claiming ownership over a parcel of land in Carmona, Cavite by virtue of Transfer Certificate of Title (TCT) No. T-320601, sought to intervene in pending Land Registration Commission (LRC) cases (LRC Case Nos. B-89-14 and B-90-6) before the Regional Trial Court (RTC) of Bacoor, Cavite. These cases involved applications for original registration of title over the same property by private respondents. Dolfo filed a motion for leave to file a complaint-in-intervention, asserting her registered ownership. The trial court denied her motion, citing that intervention is procedurally improper in original land registration proceedings, which are in rem, and noting that an order of general default had already been issued. The court also gave weight to reports from the Land Registration Authority and the National Bureau of Investigation indicating that Dolfo’s certificate of title was issued without legal basis and bore a forged signature of the Register of Deeds. Subsequently, the RTC rendered a joint decision recognizing the rights of the private respondents and ordering the issuance of a decree of registration in their favor.
ISSUE
The primary issue is whether the Court of Appeals erred in upholding the trial court’s denial of Dolfo’s motion for intervention in the land registration cases.
RULING
The Supreme Court denied the petition and affirmed the Court of Appeals’ decision. The Court held that a motion for intervention is not the proper remedy in original land registration proceedings. Citing Sections 14 and 25 of the Property Registration Decree (P.D. No. 1529), the Court explained that the only parties in such in rem proceedings are the applicant and the oppositor. The proper procedure for a party with an interest is to seek the lifting of the order of general default and, if granted, to file an opposition to the application. Allowing intervention would be inconsistent with the nature of registration proceedings, whose sole object is the adjudication of title for registration, not the resolution of conflicting claims of ownership which are more appropriately litigated in ordinary civil actions.
Furthermore, the Court found no error in the lower courts’ refusal to admit the intervention, as they had made a factual finding that Dolfo’s title was of doubtful authenticity based on official reports. The Torrens system does not vest title but merely confirms an existing one; thus, a certificate of title is not indefeasible if its issuance is fundamentally flawed. Since a separate action for the annulment of Dolfo’s title was already pending, allowing her to intervene in the LRC cases would be premature and would not prevent multiplicity of suits. Dolfo was not without remedy, as she could pursue the annulment case and, if successful, challenge the registration decree or seek damages.