GR 182913; (November, 2013) (Digest)
G.R. No. 182913; November 20, 2013
Republic of the Philippines vs. Antonio, Feliza, Nemesio, Alberto, Felicidad, Ricardo, Milagros and Cipriano, all surnamed Bacas; Emiliana Chabon, et al.
FACTS
The Republic filed complaints for annulment of Original Certificates of Title (OCT No. 0-358 and OCT No. 0-669) issued to the Bacas and Chabon families, respectively. The titles cover lands within the area proclaimed as Camp Evangelista Military Reservation in 1938 by Presidential Proclamation No. 265. The proclamation reserved the land for military use but was “subject to private rights, if any there be.” The Bacases and Chabons successfully obtained registration decrees in 1968 and 1976, respectively, under the Land Registration Act (Act No. 496). The Republic did not appeal these decrees. Instead, it later filed separate civil actions for annulment, arguing the lands were part of the inalienable military reservation and thus could not be registered as private property.
ISSUE
Whether the Republic’s action for annulment of title is barred by the doctrine of incontrovertibility and indefeasibility of a Torrens title.
RULING
Yes, the action is barred. The Supreme Court affirmed the dismissal of the Republic’s complaints. The Court emphasized the fundamental principle of indefeasibility of a Torrens title one year after the decree of registration. Under Section 38 of the Land Registration Act, a decree becomes incontrovertible upon the expiration of one year from its entry. The Republic filed its annulment cases beyond this one-year period. The Court rejected the Republic’s argument that the titles were void ab initio because the land was allegedly inalienable. A decree of registration can only be assailed within one year from its issuance on grounds of actual fraud, and the Republic failed to prove such fraud. The principle of indefeasibility applies even against the State. The proper remedy for the Republic was a timely appeal from the Land Registration Court’s decision, not a collateral attack via an annulment suit filed years later. The existence of Proclamation No. 265, being subject to private rights, did not automatically render the land inalienable if private rights were proven, as the registration courts had found. The State’s failure to seasonably challenge the decrees precluded it from subsequently disputing the titles.