G.R. No. 156380 ; September 8, 2004
DOMINGO A. CAÑERO, petitioner, vs. UNIVERSITY OF THE PHILIPPINES, respondent.

FACTS

Petitioner Domingo Cañero filed a petition for reconstitution of title over a lot in Quezon City, alleging the original title was destroyed by fire. The Regional Trial Court granted the petition after due publication and notice, and a new title was issued in his and his spouse’s name. Respondent University of the Philippines (UP) did not oppose the reconstitution proceedings. Subsequently, Cañero discovered that UP claimed ownership of the same lot and had a tax declaration in its name. Cañero’s own tax declaration carried an annotation that his property appeared to duplicate UP’s property. He then filed an action to quiet title, arguing that UP’s failure to object during reconstitution barred its claim and that his reconstituted title was conclusive evidence of ownership.
UP moved to dismiss, asserting ownership tracing back to a 1914 title and continuous possession of the land, which forms part of its Diliman campus. It argued that the reconstituted title was void, as the land was already registered under UP’s name under the Torrens system. The trial court ruled in favor of Cañero, but the Court of Appeals reversed, declaring UP as the true owner and nullifying Cañero’s reconstituted title.

ISSUE

Whether the reconstituted title issued to Cañero prevails over UP’s pre-existing Torrens title, and whether UP’s failure to participate in the reconstitution proceedings constitutes res judicata.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals. The legal logic is anchored on the indefeasibility and conclusiveness of a Torrens title. UP’s title, derived from a valid original certificate of title, is evidence of an incontrovertible and indefeasible ownership. A reconstitution proceeding merely restores a lost or destroyed title; it does not adjudicate ownership or validate a void title. Since the land was already registered under UP’s name prior to the reconstitution, Cañero’s reconstituted title is void ab initio. The Court emphasized that no title can be reconstituted over a parcel of land already covered by a subsisting Torrens title in another’s name.
Furthermore, the principle of res judicata does not apply. A judgment rendered in a reconstitution case, which is in rem, binds the whole world only if the court had valid jurisdiction. However, jurisdiction requires that the subject property is capable of registration. Here, as the land was already registered under UP, the trial court had no jurisdiction to reconstitute a new title over it. Consequently, UP’s failure to oppose the reconstitution did not estop it from challenging the void title. The Court upheld UP’s ownership, noting its long-standing, continuous possession and the public interest in preserving the integrity of its campus lands.