GR 159674; (June, 2006) (Digest)
G.R. No. 159674 June 30, 2006
SAMUEL ESTRIBILLO, ET AL., Petitioners, vs. DEPARTMENT OF AGRARIAN REFORM and HACIENDA MARIA, INC., Respondents.
FACTS
Petitioners are recipients of Emancipation Patents (EPs) and corresponding Transfer Certificates of Title (TCTs) over parcels of land in Agusan del Sur, formerly part of a 527.8308-hectare property owned by respondent Hacienda Maria, Inc. (HMI). The land was placed under Operation Land Transfer pursuant to Presidential Decree No. 27. HMI actively participated in the process, executing a Deed of Assignment of Rights in favor of the petitioners and others, which was annotated on its Original Certificate of Title. From 1984 to 1988, EPs and TCTs were issued to the petitioners covering the entire area.
In 1997, HMI filed petitions with the Regional Agrarian Reform Adjudicator (RARAD) seeking a declaration of erroneous coverage over 277.5008 hectares of the land, claiming it was not devoted to rice or corn and was untenanted when P.D. No. 27 took effect. The RARAD granted HMI’s petition, declaring the petitioners’ TCTs and EPs void and ordering their cancellation. The Department of Agrarian Reform Adjudication Board (DARAB) and the Court of Appeals affirmed this decision.
ISSUE
Whether the Court of Appeals erred in affirming the cancellation of the petitioners’ Emancipation Patents and Transfer Certificates of Title.
RULING
Yes. The Supreme Court reversed the Court of Appeals and reinstated the petitioners’ titles. The legal logic centers on the indefeasibility and incontrovertibility of a Torrens title once issued. An Emancipation Patent, upon its registration and the issuance of a corresponding TCT, becomes a veritable Torrens title. Such a title can no longer be challenged on the ground that the land is not covered by P.D. No. 27. The Court emphasized that the validity of a certificate of title can be assailed only in a direct proceeding, not collaterally. The proceedings before the RARAD constituted a collateral attack on the petitioners’ titles, which is impermissible.
Furthermore, HMI was estopped from questioning the coverage after having voluntarily submitted the land to agrarian reform, actively participated in all proceedings, received compensation, and executed a Deed of Assignment. Its long inaction—filing the petition only in 1997, years after the EPs were issued—constituted laches. The Court held that the issuance of the EPs and TCTs had rendered the matter of coverage moot and academic, as the titles had become indefeasible. The DARAB and the CA therefore committed reversible error in canceling the titles based on a collateral attack.