G.R. No. L-23243; January 26, 1937
Virginia Yumul, plaintiff-appellant, vs. Cayetano Rivera and Julia Rita Dizon, defendants-appellees.

FACTS

Plaintiff Virginia Yumul sought to compel defendants Cayetano Rivera and Julia Rita Dizon to convey to her two parcels of land in Concepcion, Tarlac, or to pay damages, alleging that the defendants obtained Torrens titles over the lands through fraud and that Rivera was merely her encargado (administrator). The defendants asserted absolute ownership evidenced by transfer certificates of title issued in their favor. The lands were portions of larger lots (Nos. 1241 and 1303) originally registered in the defendants’ names through voluntary registration proceedings in 1912 and 1919, and later confirmed via cadastral proceedings in 1926. Yumul did not present any adverse claim in those registration proceedings.

ISSUE

Whether the defendants, as registered owners under the Torrens system, can be compelled to reconvey the lands to the plaintiff based on an alleged trust or fiduciary relationship.

RULING

No. The Supreme Court affirmed the trial court’s judgment absolving the defendants. The defendants’ legal title, evidenced by Torrens certificates, became absolute and irrevocable after one year from the final decrees of registration. The Torrens system provides that a certificate of title is conclusive evidence of ownership, freeing the land from all prior unregistered claims. While an action for reconveyance based on a breach of trust can proceed against a registered owner, the evidence to establish such a fiduciary relationship must be clear and convincing. Here, the parol evidence presented by Yumul was insufficient to prove that Rivera was her encargado. The preponderance of evidence showed the defendants acquired the lands through purchase, including from Yumul herself. Therefore, no trust existed, and the defendants, as absolute owners, are not liable to reconvey or account for the lands’ administration.

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