GR 165014; (July, 2013) (Digest)
G.R. No. 165014; July 31, 2013
HEIRS OF ALEJANDRA DELFIN, et al., Petitioners, vs. AVELINA RABADON, et al., Respondents.
FACTS
Respondents filed an action to recover ownership and possession of a parcel of land, alleging it was originally owned by their predecessor, Emiliana Bacalso, under a lost decree. They presented an LRA certification and a daybook entry from the Register of Deeds indicating the issuance of Decree No. 98992 to Emiliana. They claimed possession through their lineage until 1988, when they discovered petitioners occupying the land. Petitioners, heirs of Alejandra Delfin, countered that their predecessor, Remegio Navares, bought the land before WWII and possessed it under a now-lost title. They relied on tax declarations, tax payments, and a prior petition for title reconstitution to support their claim of ownership.
ISSUE
Whether the Court of Appeals erred in reversing the trial court and ruling that respondents have a better right to ownership and possession of the disputed property.
RULING
The Supreme Court denied the petition and affirmed the CA decision. The core legal logic rests on the hierarchy of evidence in land ownership disputes. Respondents established a superior claim by proving the land was originally registered under the Torrens system in the name of their predecessor, Emiliana Bacalso, via the LRA certification and the daybook entry. These are official records that constitute prima facie evidence of the facts stated therein. Once a decree of registration is issued, the title becomes incontrovertible after one year, and the property cannot be acquired by prescription or adverse possession.
Petitioners’ evidence was insufficient to overcome this registered title. Tax declarations and receipts are not conclusive proof of ownership but merely indicia of claim. Their claim of a lost title in Remegio’s name was undermined by the dismissal of their reconstitution petition, where a Register of Deeds representative testified that the alleged title did not cover the subject lot. The Court emphasized that a certificate of title serves as the best proof of ownership, and respondents’ evidence traced back to this original certificate. Petitioners’ possession, however long, could not ripen into ownership against a registered title. The defense of laches was also unavailing, as laches cannot vest title where none exists, especially against a registered owner.