G.R. No. 26689 , December 16, 1927
LEON TEMPORAL, et al., plaintiffs-appellants, vs. FERNANDO MATEO and FELISA MONTALON, defendants-appellees.

Ponente: Chief Justice Avanceña

FACTS

Martin Temporal owned certain lands. In 1882, he mortgaged them to Pedro Lopez de Leon. The defendants, spouses Fernando Mateo and Felisa Montalon, applied for and obtained original registration of these lands in their names in 1917. In support of their application, they presented two documents: (1) Exhibit 3, purportedly dated August 6, 1911, showing that Martin Temporal’s grandsons (Leon, Jose, and Prudencio Temporal) redeemed the lands from the mortgagee; and (2) Exhibit A, dated August 21, 1911, showing that the same grandsons sold the lands to the defendants.

The plaintiffs, who are heirs of Martin Temporal (his grandchildren and great-grandchild), filed this action for damages against the defendants. They alleged that the defendants acquired title through fraud, specifically by presenting falsified documents (Exhibits A and 3) in the registration proceedings. They claimed Exhibit 3’s true date was September 13, 1911, and was altered to August 6 to hide that the sale to defendants occurred before the redemption.

Previously, a certain Florencia de Dios had filed an action to annul the defendants’ title, making the same allegation of falsified documents, which was supported by the testimonies of plaintiffs Leon and Jose Temporal. In that prior case, Leon and Jose testified that Florencia de Dios was the true owner, having bought the lands from Martin Temporal, and that they had no rights to the property. Both the trial court and the Supreme Court dismissed Florencia de Dios’s action.

ISSUE

Did the plaintiffs sufficiently prove that the defendants committed fraud in obtaining the certificate of title, thereby entitling the plaintiffs to damages?

RULING

NO. The Supreme Court affirmed the trial court’s judgment dismissing the complaint.

1. On the Alleged Falsification of Exhibit 3: The Court found no sufficient proof that the document was falsified. The alleged alteration (the month “August” being erased and “September” written over it in the notarial ratification) only pertained to the date of notarization, not the execution date of the document itself. Even assuming an alteration occurred, there was no proof that the defendants participated in it.

2. On the Alleged Falsification of Exhibit A: The Court found no proof that this deed of sale was falsified. Plaintiff Leon Temporal himself admitted signing it, although he claimed he was misled into believing it was a sale by Florencia de Dios. The Court found this claim inconsistent with his present assertion of ownership. Furthermore, Leon Temporal collected rent from the defendants for three years after signing the document, which contradicted his claim of lack of knowledge or consent.

3. On the Plaintiffs’ Credibility and Inaction: The Court noted the contradictory conduct of plaintiffs Leon and Jose Temporal. In the prior case filed by Florencia de Dios, they testified under oath that they had no rights to the land and that Florencia de Dios was the owner. Now, in this case, they claim to be heirs and owners. This inconsistency severely undermined their credibility. Moreover, the alleged fraud pertained to documents presented during the registration proceedings. The plaintiffs took no steps to contest these documents or protect their rights during those proceedings. Under such circumstances, the burden was on them to present complete and convincing proof of fraud, which they failed to do.

Therefore, the plaintiffs failed to substantiate their claim of fraud, and the defendants’ certificate of title, having been issued in a registration proceeding, must be upheld.