G.R. No. 169985 ; June 15, 2011
MODESTO LEOVERAS, Petitioner, vs. CASIMERO VALDEZ, Respondent.

FACTS

Maria Sta. Maria and Dominga Manangan were the registered owners (¾ and ¼ pro-indiviso, respectively) of a parcel of land covered by OCT No. 24695. In 1932, Sta. Maria sold her ¾ share to Benigna Llamas. Upon Benigna’s death in 1944, her share was willed equally to her sisters Alejandra and Josefa Llamas. On June 14, 1969, Alejandra’s heirs sold their share (roughly 10,564 sq.m.) to respondent Casimero Valdez. On the same date, Josefa sold her share (the subject property) to both Valdez and petitioner Modesto Leoveras. Also on June 14, 1969, Valdez and Leoveras executed an Agreement allotting their portions: 3,020 sq.m. (residential) to Leoveras and 7,544.27 sq.m. to Valdez. On June 8, 1977, they executed an Affidavit of Adverse Claim over the subject property and took possession of their respective portions.
In 1996, Valdez discovered that Leoveras had obtained two TCTs in his name: TCT No. 195812 (3,020 sq.m.) and TCT No. 195813 (1,004 sq.m.), totaling 4,024 sq.m. The Register of Deeds furnished Valdez with documents (collectively, petitioner’s documents) including: (1) two deeds of absolute sale dated June 14, 1969, purportedly executed by Sta. Maria; (2) a Deed of Absolute Sale (Benigna Deed) dated June 14, 1969, purportedly executed by Benigna Llamas conveying portions to Valdez, Leoveras, and Virgilia Meneses; (3) a Subdivision Plan; and (4) an Affidavit of Confirmation of Subdivision dated May 3, 1994 (Affidavit), purportedly signed by Valdez, Leoveras, Meneses, and Manangan, confirming the subdivision of the entire OCT No. 24695, including Lot 3 (1,004 sq.m.) to Leoveras.
Valdez filed a complaint for Annulment of Title, Reconveyance and Damages, seeking the reconveyance of the 1,004 sq.m. portion (disputed property) covered by TCT No. 195813, arguing Leoveras was entitled only to 3,020 sq.m. per their Agreement. He contested the authenticity of the petitioner’s documents, asserting that Benigna could not have executed the 1969 deed as she died in 1944, and Sta. Maria could not have sold her share in 1969 as she had already sold it in 1932. He also denied signing the Affidavit. Leoveras defended that the parties had delineated their portions before acquisition, that he actually possessed 4,024 sq.m., and that the Affidavit corrected a mistake in the Agreement.
The RTC dismissed the complaint, finding Valdez failed to prove the documents were fabricated. The CA reversed, ruling against the authenticity of the Benigna Deed and the Affidavit, noting Benigna’s death certificate made her 1969 execution impossible and observing discrepancies in Valdez’s signatures. The CA declared both TCTs null and void and ordered Leoveras to reconvey the subject parcels to Valdez. Leoveras appealed, claiming the CA erred by ordering reconveyance of both parcels when Valdez only sought reconveyance of the disputed property (TCT No. 195813).

ISSUE

Whether the Court of Appeals erred in declaring both TCT No. 195812 and TCT No. 195813 null and void and ordering their reconveyance to respondent Casimero Valdez.

RULING

The Supreme Court denied the petition and affirmed the CA decision with modification. The Court held that the CA correctly declared TCT No. 195813 null and void, as it was based on forged and spurious documents—specifically, the Benigna Deed (executed by a person already deceased) and the Affidavit (containing a forged signature of Valdez). These documents were essential for the issuance of the title, and their invalidity vitiates the title. However, the Court found that the CA erred in also nullifying TCT No. 195812. The respondent’s complaint and evidence were directed at annulling TCT No. 195813 and reconveying the 1,004 sq.m. disputed property. TCT No. 195812, covering the 3,020 sq.m. portion, was not assailed on the same grounds of forgery; it corresponded to the area expressly allotted to Leoveras in the valid June 14, 1969 Agreement between the parties. The petitioner’s own evidence showed he was entitled to this 3,020 sq.m. portion. Therefore, only TCT No. 195813, covering the disputed 1,004 sq.m., was declared null and void. Leoveras was ordered to reconvey that portion to Valdez. The Court emphasized that ownership is distinct from registration, and a title based on void documents confers no valid ownership.