GR 157447; (April, 2005) (Digest)
G.R. No. 157447. April 29, 2005
NEMENCIO C. EVANGELISTA, ET AL., Petitioners, vs. CARMELINO M. SANTIAGO, Respondent.
FACTS
Petitioners claimed ownership of parcels of land in Rodriguez, Rizal, based on Deeds of Assignment executed by Ismael Favila in 1994. Favila claimed to be an heir of Don Hermogenes Rodriguez, who was allegedly granted the vast “Hacienda Quibiga” under a Spanish title. Petitioners alleged they entered the land in exchange for labor. They later discovered the property was covered by Transfer Certificates of Title (TCTs) in the name of respondent Carmelino M. Santiago, derived from Original Certificate of Title (OCT) No. 670 issued in 1913. Facing eviction, petitioners filed an action to declare OCT No. 670 and all derivative titles null and void, contending the OCT was fake due to numerous alleged defects, including improper signatures and inconsistencies in dates.
Respondent argued petitioners had no legal capacity to sue and stated no cause of action. He asserted the incontrovertibility of his Torrens titles, which originated from a 1913 decree. He further contended that any Spanish title claimed by petitioners could no longer be used as evidence of ownership under Presidential Decree No. 892. Respondent also raised the defense of prescription, noting the action was filed over 83 years after OCT No. 670’s issuance.
ISSUE
Whether the Court of Appeals erred in affirming the dismissal of petitioners’ complaint for declaration of nullity of OCT No. 670 and the subsequent titles in respondent’s name.
RULING
The Supreme Court denied the petition and affirmed the lower courts’ rulings. The legal logic is anchored on the principles of indefeasibility and incontrovertibility of a Torrens title. OCT No. 670, issued in 1913 pursuant to a judicial decree, became incontrovertible after one year from its issuance. An action to annul a title must be based on fraud, and such an action prescribes one year from the decree of registration. Petitioners filed their case in 1996, which is clearly barred by prescription. The Court emphasized that a Torrens certificate of title serves as conclusive evidence of ownership, and a collateral attack on its validity is prohibited.
Furthermore, petitioners’ claim, based on a purported Spanish title via Favila, is untenable. Presidential Decree No. 892 expressly discontinued the use of Spanish titles as evidence of land ownership. Petitioners failed to prove any registrable right superior to respondent’s titled ownership. Their possession, even if alleged, cannot prevail over a duly registered Torrens title. The Court upheld the presumption of regularity in the issuance of OCT No. 670 and found no compelling reason to disturb the findings of the lower courts.