GR 205559; (December, 2020) (Digest)
G.R. No. 205559, December 02, 2020
Nicasio Macutay, Petitioner, vs. Sosima Samoy, Alfredo Granil, Rene Acorda, Noblito Samoy and Sibirino Roque, Respondents.
FACTS
Petitioner Nicasio Macutay, registered owner under OCT No. P-20478, filed an accion reinvindicatoria against respondents to recover possession of a three-hectare portion of his titled land in Tumauini, Isabela. He traces his title to his stepfather, Fortunato Manuud. Respondents assert possession as tenants of the heirs of Urbana Casasola, who held an earlier homestead patent (OCT No. P-4319, later TCT No. T-8058) that allegedly includes the disputed area. The conflict originates from a 1955 protest by Fortunato against Urbana’s patent, which was dismissed by the Director of Lands. Although Fortunato’s heirs secured a favorable 1977 court order reinstating the protest, they did not pursue it. Nicasio obtained his title in 1972, decades after Urbana’s registration.
ISSUE
Whether the accion reinvindicatoria against the respondents, who are mere possessors claiming under a different registered owner, is the proper remedy to recover ownership and possession of the disputed land.
RULING
The Supreme Court denied the petition, affirming the dismissal of the complaint. The Court held that an accion reinvindicatoria is an action to recover ownership based on the plaintiff’s better right of ownership. For it to prosper, the plaintiff must prove not just title but that he has a better right to possess than the defendant. Critically, the action must be directed against the current owner of the property being claimed. Here, the respondents are not the registered owners but mere possessors claiming rights under Eugenio Vehemente, the successor to Urbana’s title (TCT No. T-8058). The real dispute is over an overlapping portion between two certificates of title—OCT No. P-20478 (Nicasio) and TCT No. T-8058 (Eugenio). Since a Torrens title cannot be attacked collaterally, the validity of Nicasio’s title relative to the earlier-issued title of Urbana/Eugenio cannot be resolved in a suit against mere possessors. The proper remedy is a direct action against the registered owner under the conflicting title, Eugenio, to settle the issue of ownership conclusively. Filing against the respondents, who derive possession from that owner, was improper.