G.R. No. L-33140 October 23, 1978
J. M. TUASON & CO., INC., ET AL., petitioners, vs. HON. HERMINIO C. MARIANO, PRESIDING JUDGE OF THE COURT OF FIRST INSTANCE OF RIZAL, ET AL., respondents.
FACTS
On October 1, 1965, respondents Manuela and Maria Aquial filed a complaint in the Court of First Instance of Rizal, praying to be declared owners of a 383-quiñon parcel of land in Balara, Marikina, Rizal. They alleged the land was acquired by their father under a Spanish title from 1877. They claimed that in 1960, they discovered the land had been fraudulently included in Original Certificate of Title (OCT) No. 735, registered in the names of the Tuasons pursuant to a 1914 land registration decree. They sought to annul OCT No. 735 and its derivative titles, which were held by petitioners J.M. Tuason & Co., Inc., the University of the Philippines, and the National Waterworks and Sewerage Authority. The spouses Jose and Saturnina Cordova, who purchased a portion from the Aquials, were allowed to intervene.
Petitioners moved to dismiss the complaint on grounds of lack of jurisdiction, prescription, laches, and prior judgment. The trial court denied the motion and proceeded, even issuing orders for the production of OCT No. 735 and related plans. This prompted petitioners to file the instant special civil actions for certiorari and prohibition, seeking to compel dismissal and to enjoin further proceedings in the case.
ISSUE
Whether OCT No. 735 and the titles derived therefrom can be collaterally attacked or declared void at this late hour by the respondents.
RULING
The Supreme Court granted the petition, directing the trial court to dismiss the complaint. The legal logic is anchored on the doctrine of stare decisis and the incontrovertible finality of OCT No. 735. The alleged irregularities in the 1914 land registration proceeding that issued the decree for OCT No. 735 are identical to issues already conclusively litigated and settled in prior jurisprudence. Specifically, the 1974 consolidated cases of Benin, Alcantara, and Pili vs. Tuason directly upheld the validity of OCT No. 735 against similar attacks. This ruling was a reiteration of a long line of decisions, including Barretto vs. Tuason and Tiburcio vs. PHHC, which have consistently sustained the title.
The Court emphasized that it is against public policy to permit the relitigation of matters already settled on the merits. The principle interest rei publicae ut finis sit litium (it is in the public interest that there be an end to litigation) demands finality. Respondents’ action constitutes a collateral attack on a Torrens title, which is impermissible after the one-year period from decree entry has lapsed. Furthermore, the defense of laches is applicable, as the Aquials asserted ownership based on a 1877 title but waited until 1965 to file suit, despite the registration under the Tuasons since 1914. Allowing the case to proceed would undermine the stability of the Torrens system and waste judicial resources. Thus, the trial court acted with grave abuse of discretion in not dismissing the case.