GR 179741; (December, 2015) (Digest)
G.R. No. 179741 December 9, 2015
HEIRS OF SPOUSES HILARIO MARINAS and BERNARDINA N. MARINAS, Petitioners vs. BERNARDO FRIANEZA, et al., Respondents
FACTS
Hilario Marinas died in 1977, survived by his wife Bernardina and ten children. In 1978, Bernardina, with her children’s consent, entered into Agricultural Leasehold Contracts with the respondents over portions of the land covered by TCT No. 137203. In 1989, Bernardina and the respondents executed a Landowner-Tenant Farmers Deed of Undertaking under Presidential Decree No. 27, transferring ownership to the respondents, who were subsequently issued Emancipation Patents. Bernardina died in 1990. In 2001, the heirs of Hilario and Bernardina filed a Complaint for Nullification of Patent and Other Documents, Reconveyance, Accounting and Damages before the DARAB.
The petitioners argued the transfers were void, alleging respondents acted in bad faith by dealing solely with Bernardina, who only owned a 1/11 share as a co-owner, and that the property was exempt from agrarian reform. They also claimed procedural defects, such as non-payment and lack of notice to all co-owners. The Regional Adjudicator and the DARAB dismissed the complaint, but the Court of Appeals reversed, declaring the Deed of Undertaking void for lack of consent from all co-owners and ordering reconveyance.
ISSUE
Whether the Court of Appeals erred in declaring the Deed of Undertaking void and ordering the reconveyance of the land to the petitioners.
RULING
The Supreme Court reversed the Court of Appeals and reinstated the DARAB decision dismissing the complaint. The legal logic is anchored on the final and indefeasible nature of the Emancipation Patents (EPs) issued to the respondents. The Court emphasized that once an EP is registered, as these were in 1989, it becomes irrevocable and confers absolute ownership upon the grantee. The petitioners’ action, filed in 2001, constituted a collateral attack on these titles, which is prohibited by law. A Torrens title cannot be altered, modified, or cancelled except in a direct proceeding.
Furthermore, the Court found the petitioners’ claims of bad faith and procedural defects unsubstantiated. The Deed of Undertaking was executed under the operational coverage of P.D. No. 27, and Bernardina’s actions were consistent with her role as the surviving spouse managing the conjugal property. The long delay of nearly twelve years from the registration of the EPs and Bernardina’s death before filing the suit militates against the petitioners’ cause. The proper remedy for questioning the issuance of the EPs was a direct proceeding for cancellation within one year from issuance, not a belated action for reconveyance. Thus, the titles of the respondents, as agrarian reform beneficiaries, are upheld.