G.R. No. 148748 . January 14, 2015.
IMELDA, LEONARDO, FIDELINO, AZUCENA, JOSEFINA, ANITA and SISA, all surnamed SYJUCO, Petitioners, REPUBLIC OF THE PHILIPPINES, Petitioner-Intervenor, vs. FELISA D. BONIFACIO and VSD REALTY & DEVELOPMENT CORPORATION, Respondents.

FACTS

Petitioners are the registered co-owners of a parcel of land (Lot No. 3-B, Psd-706, part of Lot No. 23-A, Psu-2345 of the Maysilo Estate) in Caloocan City, under Transfer Certificate of Title (TCT) No. T-108530 issued on March 26, 1984. They and their predecessors-in-interest have been in open, continuous, and uninterrupted possession since 1926, with title traceable to TCT No. 10301 issued in 1926 to Monica Jacinto Galauran, and have paid real property taxes since 1949. The land was leased to Manufacturer’s Bank and Trust Company and later to Chan Heng.
In 1994, petitioners discovered that respondent Felisa D. Bonifacio, who was a sub-lessee through Kalayaan Development Corporation (itself a sub-lessee of Manufacturer’s Bank), had obtained TCT No. 265778 over the same land on March 29, 1993. This title was issued pursuant to an Order dated October 8, 1992, of the Regional Trial Court (RTC), Branch 125, Caloocan City, in L.R.C. Case No. C-3288, which granted Bonifacio’s petition for segregation of Lots 23-A-4-B-2-A-3-A and 23-A-4-B-2-A-3-B from Original Certificate of Title (OCT) No. 994 of the Register of Deeds of Rizal, based on a Deed of Assignment from Eleuteria Rivera Bonifacio. The Register of Deeds issued TCT No. 265778 before the RTC Order became final on April 6, 1993.
Petitioners filed a Petition (Civil Case No. C-366) before RTC Branch 126, Caloocan City, seeking nullification of TCT No. 265778, which was treated as a special civil action for quieting of title. They later discovered that Bonifacio had sold the land to respondent VSD Realty & Development Corporation, which was issued TCT No. 285313. The RTC Branch 126 dismissed the petition, ruling that petitioners failed to prove their title originated from OCT No. 994 or to overcome the presumption of validity of Bonifacio’s title. The Court of Appeals affirmed the RTC decision.

ISSUE

Whether the Court of Appeals erred in affirming the dismissal of petitioners’ action for quieting of title and in upholding the validity of respondents’ titles (TCT No. 265778 and TCT No. 285313) despite petitioners’ prior registered title (TCT No. T-108530) and long-standing possession.

RULING

The Supreme Court granted the petition, reversed the Court of Appeals Decision and Resolution, and declared petitioners’ TCT No. T-108530 valid and superior. Respondents’ TCT No. 265778 and TCT No. 285313 were declared null and void. The Register of Deeds of Caloocan City was ordered to cancel these titles and reinstate petitioners’ title.
The Court held that a Torrens title is irrevocable and indefeasible, and the system aims to quiet title to land. Petitioners’ title, traced back to 1926 and supported by tax payments and possession, was superior to respondents’ title, which derived from a questionable segregation from OCT No. 994. The issuance of TCT No. 265778 before the RTC Order became final was irregular. Moreover, respondents’ title was void, as it covered the same land already registered under petitioners’ name, violating the principle that registration does not validate a void title. The Court emphasized that a title originating from a void source confers no rights, and the first registrant in good faith prevails. Petitioners’ undisturbed possession and prior registration established their rightful ownership.