GR 160832; (October, 2006) (Digest)
G.R. No. 160832 October 27, 2006
The Heirs of Emilio Santioque, represented by Felimon W. Santioque, petitioners, vs. The Heirs of Emilio Calma, Fabian Calma, Agatona Calma, and Demetria Calma, represented by Lope Akol and Lucia Calma-Akol, and the Register of Deeds of the Province of Tarlac, respondents.
FACTS
The petitioners, heirs of Emilio Santioque, filed a complaint for declaration of nullity of title and reconveyance. They claimed that on March 31, 1932, Emilio Santioque was granted Homestead Patent No. 18577, and Original Certificate of Title (OCT) No. 1112 was issued to him on April 21, 1932, over a 20.5464-hectare lot in Tarlac. However, they possessed no copy of this OCT. Upon verification, they discovered the property was registered under the names of the Calma heirs under Transfer Certificate of Title (TCT) No. 19181, issued in 1953, which was derived from a prior TCT.
The respondents, the Calma heirs, asserted ownership through their TCTs and argued the action was barred by prescription and laches. The trial court dismissed the complaint, finding the petitioners failed to prove their claimed title. The Court of Appeals affirmed, prompting this petition.
ISSUE
Whether the petitioners sufficiently proved their ownership over the disputed land to warrant the nullification of the respondents’ titles and reconveyance.
RULING
The Supreme Court denied the petition and affirmed the lower courts’ decisions. The petitioners failed to discharge the burden of proof required to establish their claimed ownership. While they presented documents from the Lands Management Bureau indicating Emilio Santioque was a claimant of Lot No. 3844, these documents were uncertified and the employees who prepared them were not presented to testify, rendering them inadmissible as evidence of title. Critically, they could not produce a copy of the alleged OCT No. 1112, and the Register of Deeds had no record of it. The absence of this original title or a certified copy was fatal to their claim.
In contrast, the respondents’ ownership was evidenced by valid and extant TCTs issued in their names. The petitioners’ action, filed decades after the alleged issuance of their title and the registration of the respondents’ titles, was also barred by laches. Their unexplained delay in asserting their right, despite alleged knowledge of the property’s existence, prejudiced the respondents who had held the land under registered titles for over forty-five years. Consequently, the petitioners’ unsubstantiated claim could not overcome the presumption of regularity favoring the respondents’ registered titles.