GR 171184; (March, 2008) (Digest)
G.R. No. 171184; March 4, 2008
BENJAMIN P. QUITORIANO, et al., Petitioners, vs. DEPARTMENT OF AGRARIAN REFORM ADJUDICATION BOARD (DARAB) and EDUARDO AGLIBOT, Respondents.
FACTS
The case involves a parcel of land, Lot 7733-B, covered by Emancipation Patent (EP) No. 151580 and Original Certificate of Title (OCT) No. 1183 in the name of respondent Eduardo Aglibot. The EP and OCT were issued pursuant to a Deed of Absolute Transfer executed in 1989 by Atty. Emiliano Rabina, representing the Heirs of Fermin Rabina, who sold the land to Aglibot, their purported tenant-farmer. Petitioners, successors-in-interest of Nicolas Quitoriano, claimed ownership over Lot 7733-B, asserting it was part of their father’s larger estate. They alleged possession since WWII and that they had allowed Severino Beniola to cultivate it. They filed a Petition for Cancellation of the EP and OCT before the DARAB, contending Aglibot was not a bona fide tenant and the sale was invalid.
The Provincial Adjudicator dismissed the petition, upholding the validity of the Deed and the titles. The DARAB and the Court of Appeals affirmed this decision. The lower tribunals found petitioners failed to substantiate their claim of ownership, as their tax declarations referenced a different, larger property. The evidence established the Rabinas as the owners who validly transferred the land to Aglibot under agrarian reform.
ISSUE
Whether the Court of Appeals erred in affirming the DARAB decisions which upheld the validity of Eduardo Aglibot’s Emancipation Patent and Certificate of Title over the subject land.
RULING
The Supreme Court denied the petition and affirmed the assailed decisions. The Court emphasized that factual findings of administrative agencies, like the DARAB, when affirmed by the Court of Appeals, are generally conclusive and binding. Petitioners failed to prove any of the recognized exceptions to this rule, such as a showing that the findings were not supported by substantial evidence.
The legal logic rests on the strength of Aglibot’s registered title. An emancipation patent, once registered, becomes an OCT and enjoys the same indefeasibility and conclusiveness as a Torrens title. To challenge such a title, the evidence must be clear, convincing, and more than a mere preponderance. Petitioners’ evidence, primarily tax declarations, was insufficient to overcome the evidentiary weight of Aglibot’s OCT. Tax declarations are not conclusive proof of ownership. Furthermore, the Court upheld the findings that Aglibot was a legitimate tenant-farmer of the Rabinas, making him a qualified grantee under Presidential Decree No. 27. The Deed of Absolute Transfer and the subsequent issuance of the EP were therefore valid. The petitioners’ claim, based on alleged possession, could not prevail against a registered title acquired in good faith.