GR 155181; (April, 2005) (Digest)
G.R. No. 155181. April 15, 2005
Liberty Ayo-Alburo, Petitioner, vs. Uldarico Matobato, Respondent.
FACTS
The case involves a 1.787-hectare rice land in Leyte owned by Dr. Victoria Marave-Tiu, covered by P.D. 27 (Operation Land Transfer). The land was originally awarded to Estanislao Ayo, the administrator-tenant. Due to old age and sickness, Estanislao requested the Department of Agrarian Reform (DAR) to register the land in the name of his adoptive daughter, petitioner Liberty Ayo-Alburo. Consequently, a Certificate of Land Transfer (CLT) and later an Emancipation Patent (EP) with a corresponding Transfer Certificate of Title were issued in petitioner’s name by 1987. Respondent Uldarico Matobato later filed a petition before the Provincial Agrarian Reform Adjudicator (PARAD) seeking cancellation of petitioner’s CLT and EP, alleging he had been the actual cultivator of the land since 1966 and that the issuance to petitioner was a mistake.
ISSUE
Whether the Emancipation Patent and title issued to petitioner should be cancelled and the land reallocated to respondent.
RULING
The Supreme Court ruled in favor of the petitioner, reversing the Court of Appeals and reinstating the DARAB decision which had upheld her title. The legal logic centers on the indefeasibility and conclusiveness of a registered Emancipation Patent. Once an EP is registered and a certificate of title is issued, the land is deemed placed under the coverage of the Torrens system. The title becomes indefeasible and incontrovertible one year from its issuance. Respondent’s action, filed nearly nine years after the title was issued, was therefore barred by prescription. The Court emphasized that the purpose of P.D. 27 is to grant ownership to tenant-farmers, and the issuance of the EP to petitioner, who was the lawful awardee, vested in her a vested right. The PARAD and the CA erred in canceling the title based on alleged cultivation by respondent, as such a collateral attack on a Torrens title is not permitted. The proper remedy for respondent, if he had a claim, was a direct proceeding within the prescribed one-year period. His failure to do so rendered petitioner’s title incontrovertible. The forfeiture of petitioner’s amortization payments in favor of respondent was also declared invalid, as she had fully paid the Land Bank, solidifying her status as the absolute owner.