GR 152021; (May, 2005) (Digest)
G.R. No. 152021 ; May 17, 2005
HEIRS OF ERNESTO V. CONAHAP, petitioners, vs. HEIRS OF PROSPERADOR REGAÑA, respondents.
FACTS
The spouses Prosperador and Milagros Regaña purchased a titled lot from Ecoland Properties in 1983. After paying the price and securing a Transfer Certificate of Title (TCT) in Prosperador’s name, they left for work abroad. Upon returning in 1984, they found the lot vacant, placed a temporary fence and a “No Trespassing” sign, and left again. In March 1988, they discovered a house occupied by Ernesto Conahap on the property. Prosperador filed an ejectment complaint and, after no settlement was reached, a suit for recovery of possession in the RTC.
In his defense, Conahap claimed the land he occupied was part of a different parcel covered by a homestead patent application filed by Ponciano Sabroso in 1982, who had allegedly permitted him to build there. He argued the titled property of the Regañas and the land he occupied were not identical, presenting survey plans and a memorandum suggesting a boundary overlap. He also noted prior ejectment cases between Ecoland and Sabroso that were dismissed for lack of jurisdiction.
ISSUE
Whether the petitioners (Conahap) can successfully resist the respondents’ (Regaña) action for recovery of possession by claiming the property is part of a public land application, despite the respondents holding a registered title to the land.
RULING
The Supreme Court denied the petition and upheld the respondents’ right to possession. The legal logic rests on the conclusiveness of judicial admissions and the indefeasibility of a Torrens title. During pre-trial, Conahap admitted that the Regañas purchased the specific lot from Ecoland and that it was titled in their names. These judicial admissions are binding and cannot be contradicted unless shown to be made through palpable mistake, which was not proven. Thus, petitioners are estopped from claiming the occupied land is not the same property titled to the respondents.
The Court emphasized that a certificate of title is incontrovertible evidence of ownership. The claim based on Sabroso’s homestead application fails because, at the time it was filed in 1982, the land was already private property owned by Ecoland and later the Regañas. An unapproved application on land already classified as private confers no rights. The prior ejectment cases involving Sabroso were irrelevant as they were dismissed on jurisdictional grounds and did not adjudicate ownership. Therefore, as registered owners, the respondents have a superior right to possess the property.