ZENAIDA ACOSTA, ET AL., Petitioners, vs. TRINIDAD SALAZAR AND ANICETA SALAZAR, Respondents.
FACTS
Respondents Trinidad and Aniceta Salazar filed a petition in 1985 for the cancellation of certain entries on OCT No. 40287, claiming the entries were void. The RTC, Branch 63, granted the petition ex parte, ordering the cancellation of entries and later directing the Register of Deeds to recall all titles derived from them. This led to the reconstitution of OCT No. 40287 and the issuance of TCT No. 219121 in the Salazars’ names in 1989. At this stage, petitioners, who were subsequent purchasers for value holding titles derived from the original OCT, filed a formal comment opposing the proceedings. The RTC, Branch 63, then issued an order withdrawing all incidents without prejudice to filing an appropriate action. The Salazars subsequently filed a complaint for quieting of title against petitioners before RTC Branch 64.
The RTC, Branch 64, dismissed the Salazars’ complaint, declaring TCT No. 219121 void and upholding the validity of the petitioners’ titles. The court found the proceedings in Branch 63 were null for lack of jurisdiction, as a land registration court cannot resolve issues of ownership without adversarial proceedings. The Salazars appealed to the Court of Appeals, which reversed the RTC, ruling that the petitioners’ titles were void for being derived from a non-existent TCT No. 9297 and that the action was not a collateral attack.
ISSUE
Whether the Court of Appeals erred in reversing the RTC and declaring the petitioners’ titles null and void.
RULING
Yes. The Supreme Court reversed the Court of Appeals and reinstated the RTC decision. The legal logic centers on jurisdiction and the indefeasibility of a Torrens title. The proceedings before RTC Branch 63 were null and void from the outset because a land registration court lacks jurisdiction to resolve issues of ownership in a non-adversarial proceeding. The order that led to the issuance of TCT No. 219121 for the Salazars was issued without jurisdiction over indispensable parties-the petitioners and other titleholders. Consequently, TCT No. 219121 is void and produces no legal effect. In contrast, the petitioners are purchasers in good faith and for value, holding titles derived from the original OCT. An action for quieting of title is not the proper remedy to challenge these titles, as it constitutes a collateral attack, which is prohibited by Section 48 of P.D. No. 1529. A certificate of title cannot be impeached collaterally; the remedy is a direct proceeding. The petitioners’ titles, having been issued under the Torrens system, are presumed valid, and the Salazars failed to overcome this presumption through a direct action. The Supreme Court emphasized that the nullity of the Branch 63 order did not retroactively invalidate the petitioners’ lawfully acquired titles.
