G.R. No. 193156. September 26, 2018
IVQ LAND HOLDINGS, INC., PETITIONER, VS. REUBEN BARBOSA, RESPONDENT.

FACTS

Respondent Reuben Barbosa filed a Petition for Cancellation and Quieting of Titles, claiming he purchased the subject property from Therese Vargas in 1978, receiving the owner’s duplicate of TCT No. 159487. He took possession and paid real estate taxes. In 2003, he discovered the tax declaration was under petitioner IVQ Land Holdings, Inc. IVQ’s title was derived from Jorge Vargas III, who also claimed acquisition from the same original owner, Kawilihan Corporation. Barbosa asserted his title’s superiority as it bore an earlier registration date. IVQ countered that Barbosa’s title was fraudulently acquired and part of a land-grabbing scheme, highlighting his 30-year delay in filing the action.
The Regional Trial Court ruled in favor of Barbosa, ordering the cancellation of IVQ’s title. The Court of Appeals affirmed. The Supreme Court initially denied IVQ’s petition but later granted a remand to the Court of Appeals for reception of additional evidence, specifically on the authenticity of the competing titles and the correct Friar Land Survey (FLS) number. The appellate court, after further proceedings, submitted a Report and Recommendation affirming the validity of Barbosa’s title and ownership.

ISSUE

Whether the Court of Appeals erred in affirming the trial court’s decision which upheld Barbosa’s ownership and ordered the cancellation of IVQ’s title.

RULING

The Supreme Court denied IVQ’s Second Motion for Reconsideration and upheld the findings of the lower courts. The legal logic rests on the principle that a certificate of title is merely evidence of ownership, not ownership itself. The Court emphasized that registration under the Torrens system does not vest title; it is the underlying transaction and validity of acquisition that are paramount. The factual findings of the trial court, affirmed by the Court of Appeals, established Barbosa’s prior purchase, possession, and tax payments, constituting a superior claim. IVQ’s new evidence, presented after remand, was found insufficient. A certification from the Land Registration Authority stating that the FLS number in IVQ’s title was a typographical error did not bolster its claim of ownership, as it pertained only to an entry in the certificate, not the validity of the title’s origin. Furthermore, IVQ’s challenge to the notarization of Barbosa’s deed of sale was deemed inconclusive, as Barbosa presented the original deed and IVQ’s counsel admitted a photocopy was a faithful reproduction. The Court found no compelling reason to overturn the consistent factual conclusions that Barbosa presented a clearer and more credible chain of title and acts of ownership, thereby meriting the remedy of quieting of title.