GR 29764; (November, 1973) (Digest)
G.R. No. L-29764 November 29, 1973
The Spouses ANDRES ENCINARES and JUANA NALAZON, applicants-appellees, vs. ENRIQUE CATIGHOD, PROCESA DOROGA and ARTEMIO DELORINO, oppositors-appellants.
FACTS
The spouses Andres Encinares and Juana Nalazon filed an application for the registration of two lots in Catarman, Northern Samar. They presented evidence of their purchase of the land from the Adan brothers, their open possession, and certifications that the land was alienable and disposable and free from prior grants. The notice of initial hearing was duly published and posted, and an order of general default was issued against the whole world except for the three oppositors: Enrique Catighod, Procesa Doroga, and Artemio Delorino.
These oppositors objected to the registration, claiming rights as lessees of the Municipality of Catarman. The trial court found that the Municipality itself, the alleged lessor, was declared in default and failed to present any evidence of ownership over the specific parcels in question. The court noted that the documents the Municipality produced pertained to different properties. Consequently, the lower court adjudicated the lots in favor of the applicant spouses, ruling that the oppositors’ derivative claims from the Municipality could not prevail.
ISSUE
Whether the Court of Appeals erred in affirming the trial court’s decision granting the application for land registration.
RULING
The Supreme Court affirmed the lower court’s decision, dismissing the appeal as without merit. The legal logic is anchored on two key principles. First, the appeal was taken directly to the Supreme Court, which, under prevailing jurisprudence, limits review to questions of law. The appellants attempted to challenge the factual findings of the trial court, which found a preponderance of evidence in favor of the applicants. The Supreme Court is not a trier of facts and found no compelling reason to disturb these factual conclusions, which were based on the applicants’ clear evidence of ownership and possession.
Second, the substantive claim of the oppositors was legally untenable. Their rights were merely derivative, stemming from an alleged lease with the Municipality of Catarman. Since the Municipality itself was in default and failed to substantiate any ownership claim over the subject lots, the oppositors could not assert a better right than their purported lessor. The Court emphasized that the adversary system requires an aggrieved party to actively assert its rights; the Municipality’s inaction was its own choice. The oppositors’ remedy, if any, lies against the Municipality for any breach of lease, not against the registered owners. The decision recognized the applicants’ registrable title without prejudice to any personal rights the oppositors might have arising from their occupation, but such rights do not constitute ownership that can block registration.