G.R. No. 173900; August 8, 2010
Gaudencio Labrador, represented by Lulu Labrador Uson, as Attorney-in-Fact, Petitioner, vs. Sps. Ildefonso Perlas and Pacencia Perlas and Sps. Rogelio Pobre and Melinda Fogata Pobre, Respondents.

FACTS

Petitioner Gaudencio Labrador is the registered owner of a 53,358-square-meter parcel of land in Zambales covered by Original Certificate of Title (OCT) No. P-3030, issued in 1973. He alleges that his father, Melecio Labrador, merely allowed respondent spouses Ildefonso and Pacencia Perlas to temporarily occupy a portion of the land in 1957-1958, on the condition they would vacate upon demand. In 1979, without petitioner’s knowledge, the Perlas spouses sold the occupied portions to respondent spouses Rogelio and Melinda Pobre. Upon discovering the sale in 1992, petitioner demanded that the Perlas spouses vacate, but they refused, prompting him to file an action for annulment of sale and recovery of possession.
Respondents present a contradictory version. They assert that Ildefonso Perlas and his family have lived on and developed a distinct parcel of land in Sitio Bolintabog since 1957, separate from Labrador’s titled property. They claim ownership over this 2,903.6-square-meter lot, supported by Tax Declaration No. 001-1390 (1994) and certifications from the Bureau of Lands (1983) stating the land is alienable and disposable public land.

ISSUE

Whether the Court of Appeals erred in affirming the Regional Trial Court’s decision which declared the respondents as the lawful owners of the disputed property.

RULING

The Supreme Court granted the petition, set aside the assailed Court of Appeals decision, and remanded the case to the trial court. The legal logic centers on the insufficiency of evidence to overcome the presumption of regularity accorded to a Torrens title and the need for a definitive factual determination on the identity of the land.
The trial court, while recognizing the validity of petitioner’s OCT No. P-3030 and the presumptions of regularity in its issuance, nevertheless ruled for respondents based on their long possession, tax declarations, and government certifications. The Court of Appeals affirmed this. The Supreme Court found this erroneous. The evidence presented by respondents—possession since 1957, tax declarations, and Bureau of Lands certifications—is not conclusive proof that the land they occupy is separate and distinct from the land covered by Labrador’s OCT. These documents do not definitively establish that the subject lot is not within the metes and bounds of the titled property. The core issue of whether the land claimed by respondents is included in or excluded from OCT No. P-3030 remains unresolved. Since the Supreme Court is not a trier of facts, it remanded the case to the trial court for further proceedings specifically to determine this critical question of land identity and overlap.