G.R. No. L-29596 October 14, 1977
JULIAN JR., SERGIO, PEDRO, LUIS and MONICA, all surnamed RODRIGUEZ, petitioners, vs. SABINA TORENO, TIMOTEO TORENO, GLICERIA BOCASE, ALEJANDRO BOCASE, BENJAMIN CAMPOREDONDO, SIMPLICIA BOCASE, PEDRO DOCASE, BERNARDO BIENVENIDO DOCASE, GREGORIA BOCASE and THE FOURTH DIVISION OF THE COURT OF APPEALS, MANILA, respondents.

FACTS

The case involves a parcel of land originally owned by Valentina Quiñones. Upon her death, the land passed to her heirs. In 1950, Original Certificate of Title No. 0-15 was issued in the names of 26 co-owners, including the respondents herein. The respondents filed a complaint for ejectment and damages against Julian Rodriguez, Sr. (petitioner’s predecessor), alleging that they are pro-indiviso registered owners and that Rodriguez had forcibly occupied a portion of the land since 1953, collecting rentals from tenants thereon.
In his defense, Rodriguez claimed he had purchased the rights to the subject portion from most of the heirs through a series of deeds of sale executed in 1940 and 1941, prior to the issuance of the title. He argued these unregistered sales were valid and that he was the rightful owner. The trial court ruled in favor of the respondents, ordering Rodriguez to vacate and pay damages. The Court of Appeals affirmed this decision.

ISSUE

Whether the unregistered deeds of sale, executed prior to the issuance of the original certificate of title, can prevail over the registered title of the respondents.

RULING

No. The Supreme Court affirmed the Court of Appeals’ decision. The legal logic is anchored on the fundamental principles of the Torrens system. A certificate of title, once issued, becomes indefeasible and serves as conclusive evidence of ownership. Claims or liens existing against the land prior to the issuance of the title, but not noted thereon, are generally cut off by the certificate. Rodriguez’s alleged purchases, though evidenced by deeds executed years before registration, were never annotated on OCT No. 0-15. Consequently, these unregistered transactions cannot bind or prejudice the respondents who are the registered co-owners. The Court found no error in the appellate court’s application of this doctrine. Furthermore, it noted the trial court’s factual finding—which was not disturbed on appeal—that the transactions were likely equitable mortgages or loan security arrangements, not absolute sales. Rodriguez’s failure, as the respondents’ former counsel in the cadastral case, to have these claims annotated or brought before the registration court bolstered this conclusion. Thus, his possession was unlawful, and he was liable for damages arising from his occupation and the cutting of trees on the property.