GR 173531; (February, 2012) (Digest)
G.R. No. 173531; February 1, 2012
LEONCIO C. OLIVEROS, represented by his heirs, MOISES DE LA CRUZ, and the HEIRS OF LUCIO DELA CRUZ, represented by FELIX DELA CRUZ, Petitioners, vs. SAN MIGUEL CORPORATION, THE REGISTER OF DEEDS OF CALOOCAN CITY, and THE REGISTER OF DEEDS OF VALENZUELA, METRO MANILA, Respondents.
FACTS
Petitioners, led by Leoncio Oliveros, sought the nullification of the title of San Miguel Corporation’s (SMC) predecessor-in-interest, Ramie Textile, Inc. (Ramitex), over Lot 1131 of the Malinta Estate. Oliveros claimed ownership by virtue of a 1956 sale, asserting that Transfer Certificate of Title (TCT) No. T-17186 was issued in his name. He filed a petition for its reconstitution after a fire allegedly destroyed the original at the Register of Deeds of Bulacan. Ramitex, which had purchased the same lot from different vendors in 1957 and subsequently consolidated it with adjacent properties, opposed the reconstitution and asserted its valid title, TCT No. T-18460. It argued that Oliveros’s title was spurious, noting that the judicial form used for TCT No. T-17186 was officially issued to a different registry. Oliveros then filed a separate complaint to declare Ramitex’s title null and void.
ISSUE
The core issue is whether Oliveros’s claim of ownership, based on TCT No. T-17186, prevails over Ramitex’s registered title, thereby warranting the nullification of Ramitex’s title and the subsequent consolidated title.
RULING
The Supreme Court denied the petition and affirmed the lower courts’ dismissal of Oliveros’s complaint. The legal logic rests on the principle that the indefeasibility and conclusiveness of a Torrens title apply only to holders of valid titles. Oliveros failed to prove the validity and authenticity of his claimed TCT No. T-17186. Critical deficiencies undermined his claim: he never presented the owner’s duplicate certificate during trial, offering only a machine copy, and his explanation for its absence was deemed unsatisfactory. Crucially, evidence from the Land Registration Authority established that the serial number of the form for his alleged title was issued to the Register of Deeds of Davao, not Bulacan, strongly indicating fabrication.
In contrast, Ramitex (and later SMC) demonstrated a clear chain of valid transactions, starting from its 1957 purchase supported by a genuine title, TCT No. T-18460. Its subsequent consolidation and subdivision of properties, leading to the issuance of a new title, were regular proceedings. The Court emphasized that a certificate of title serves as incontrovertible evidence of ownership only when the title itself is genuine. Since Oliveros’s title was found to be non-existent and spurious, he could not invoke the protective mantle of the Torrens system to attack Ramitex’s valid and regularly derived title. The burden of proof rested on Oliveros to establish the superiority of his claim, which he failed to discharge.