G.R. No. 192393, March 27, 2019
FIL-ESTATE MANAGEMENT, INC., ET AL., PETITIONERS, VS. REPUBLIC OF THE PHILIPPINES AND SPOUSES SANTIAGO T. GO AND NORMA C. GO, RESPONDENTS.

FACTS

Respondents Spouses Go filed an application for original registration of title over several parcels of land in Las Piñas City. Petitioners Fil-Estate Management, Inc., et al., opposed the application, claiming that the lands applied for overlapped with properties already covered by their existing Torrens titles. The Regional Trial Court (RTC) denied the Spouses Go’s application, finding they failed to prove the lands were alienable and disposable and that their possession met the required duration. However, the RTC also ruled that petitioners failed to distinctly establish their claim of overlapping titles.
The Court of Appeals affirmed the RTC decision denying registration. Petitioners elevated the case, arguing the appellate court erred in not ruling on the overlapping issue and that the RTC’s confirmation of the Spouses Go’s title, albeit erroneous, constituted a collateral attack on their own titles.

ISSUE

Whether the courts erred in their treatment of the petitioners’ claim of overlapping titles and whether such claim was sufficiently established.

RULING

The Supreme Court denied the petition. The legal logic proceeds from the jurisdiction of land registration courts and the nature of factual findings on appeal. A land registration court is tasked under Section 29 of P.D. No. 1529 to resolve all conflicting claims. While the RTC correctly denied the application for the Spouses Go’s failure to meet the requisites for original registration, its concomitant finding that petitioners did not convincingly prove overlapping is a factual determination. The petitioners presented a survey plan, but the RTC found this evidence insufficient to distinctly establish the alleged overlap. The Republic and the Spouses Go presented no contrary survey, but the burden remained on the petitioners to prove their affirmative claim.
The Court of Appeals’ failure to separately rule on the overlapping issue stemmed from its tacit affirmation of the RTC’s factual finding, which was made clear when it denied petitioners’ motion for reconsideration raising the point. In a Rule 45 petition, the Supreme Court is not a trier of facts and cannot review factual questions, such as the sufficiency of evidence to prove overlapping. Absent a clear, categorical declaration from the lower courts that an overlap exists, no cloud of doubt is cast upon the petitioners’ Torrens titles, nor did the proceedings constitute a collateral attack on them. The petition was correctly denied.