GR 144915; (February, 2004) (Digest)
G.R. No. 144915 ; February 23, 2004
CAROLINA CAMAYA, FERDINAND CAMAYA, EDGARDO CAMAYA and ANSELMO MANGULABNAN, petitioners vs. BERNARDO PATULANDONG, respondent.
FACTS
Rufina Reyes executed a will in 1972, devising Lot No. 288-A to her grandson, Anselmo Mangulabnan. The will was probated in 1973. Subsequently, in June 1973, Reyes executed a codicil modifying the will, stating that Lot No. 288-A was to be inherited in equal one-fifth shares by her four children (including respondent Bernardo Patulandong) and Mangulabnan. Upon Reyes’s death in 1988, Mangulabnan demanded the title from Patulandong, the appointed executor, who refused, citing the codicil. Mangulabnan filed an action for partition. The trial court in 1989 ordered partition but explicitly stated its decision was “without prejudice… to the probate of the codicil.”
Patulandong then filed a petition for the probate of the codicil. Meanwhile, based on the partition decision, Mangulabnan obtained title to the lot and sold it to petitioners Carolina, Ferdinand, and Edgardo Camaya, who were issued new titles. In 1996, the probate court admitted the codicil to probate. It also declared the titles of Mangulabnan and the Camayas null and void and ordered the Register of Deeds to cancel them and issue new titles in accordance with the codicil. The Court of Appeals affirmed this decision.
ISSUE
Whether the probate court, in allowing the codicil to probate, acted within its jurisdiction in declaring the transfer certificates of title of Mangulabnan and the Camayas null and void.
RULING
The Supreme Court granted the petition in part. It affirmed the probate of the codicil but set aside the portions of the lower courts’ decisions that nullified the titles and ordered their cancellation. The legal logic is grounded in the limited jurisdiction of a probate court. A probate court’s primary authority is to determine the extrinsic validity of a will or codicil—that is, whether it was executed with the requisite formalities and whether the testator was of sound mind. It does not have jurisdiction to adjudicate questions of ownership or title to properties, which are substantive issues.
The declaration that the titles were null and void and the order for their cancellation constituted a collateral attack on the certificates of title. Under the Torrens system, a certificate of title is conclusive evidence of ownership and cannot be impeached collaterally. Any challenge to its validity must be done in a direct proceeding specifically instituted for that purpose, such as an action for reconveyance or annulment of title. Therefore, while the probate court correctly allowed the codicil, it exceeded its jurisdiction by ruling on the validity of the titles. The rights of the heirs under the codicil must be pursued in a separate, appropriate action.