G.R. No. 160684, September 2, 2015.
CLT REALTY DEVELOPMENT CORPORATION, Petitioner, vs. HI-GRADE FEEDS CORPORATION, REPUBLIC OF THE PHILIPPINES (through the OFFICE OF THE SOLICITOR GENERAL), REGISTRY OF DEEDS OF METRO MANILA, DISTRICT III, CALOOCAN CITY, and the COURT OF APPEALS, Respondents.

FACTS

The dispute involves overlapping properties derived from the Maysilo Estate, specifically from Original Certificate of Title (OCT) No. 994. Petitioner CLT Realty Development Corporation (CLT) is the registered owner of TCT No. T-177013. Respondent Hi-Grade Feeds Corporation (Hi-Grade) is the registered owner of two parcels of land covered by TCT Nos. 237450 and T-146941, which it traces back to TCT No. 4211, a derivative title of OCT No. 994. CLT filed a case for Annulment of Transfer Certificates of Title, Recovery of Possession, and Damages against Hi-Grade before the Regional Trial Court (RTC) of Caloocan City. CLT argued that Hi-Grade’s title is null and void, alleging that TCT No. 4211 and its derivative titles are fake and spurious based on several infirmities, including inconsistencies in language, dates, survey plans, and tie points, and a forensic report indicating TCT No. 4211 was prepared in the 1940s, not 1918. Hi-Grade presented its line of title tracing back to OCT No. 994. The RTC ruled in favor of CLT, declaring Hi-Grade’s titles null and void. The Court of Appeals reversed the RTC decision, annulled CLT’s title, and affirmed Hi-Grade’s titles. CLT elevated the case to the Supreme Court via a Petition for Review on Certiorari.

ISSUE

The core issue is the validity of the competing titles of CLT and Hi-Grade, specifically whether Hi-Grade’s titles, derived from TCT No. 4211, are genuine and superior to CLT’s title.

RULING

The Supreme Court reversed the Court of Appeals decision and reinstated the RTC decision. The Court held that Hi-Grade failed to prove the genuineness and due execution of its predecessor title, TCT No. 4211. The burden of proof was on Hi-Grade as the party alleging the validity of its titles. The Court found that Hi-Grade did not present the original of TCT No. 4211 or a certified true copy from the custodian, nor did it provide a credible explanation for its absence. The alleged infirmities in TCT No. 4211 and its derivatives, as presented by CLT, including the forensic finding that it was prepared in the 1940s, remained unrebutted. The Court of Appeals erred in relying on the Senate Report, as it was not properly presented as evidence and its contents were not subject to judicial notice for the truth of the facts stated therein. Furthermore, Hi-Grade’s possession and tax payments were not conclusive evidence of ownership. Therefore, Hi-Grade’s titles, TCT Nos. 237450 and T-146941, were declared null and void, and CLT’s title, TCT No. T-177013, was upheld.