G.R. No. 33166 May 29, 1989
A.D. GUERRERO, PHILIPPINE NATIONAL BANK and SHERIFF OF QUEZON CITY, petitioners, vs. MERCEDES P. JUNTILLA and COURT OF APPEALS, respondents.

FACTS

The case originated from a 1957 judgment against Alipio Juntilla and a corporation. To satisfy the debt, a property registered under Alipio’s name, with a notation of his marriage to Mercedes Juntilla, was levied upon and sold at public auction to the Philippine National Bank (PNB) in 1958. After the redemption period lapsed, the court ordered the issuance of a new title to PNB in 1965 and later authorized an alias writ of execution for possession. The sheriff executed the writ and delivered possession to PNB in June 1968. PNB had previously agreed to sell the property to A.D. Guerrero, who took physical possession thereafter.
On June 6, 1968, Mercedes Juntilla filed a complaint seeking to nullify the sheriff’s sale and to be restored to possession. She alleged that the debt was corporate, not conjugal, and thus her alleged one-half conjugal share in the property could not be held liable. She claimed separate ownership based on a prior Juvenile Court judgment. The trial court granted a preliminary mandatory injunction in her favor. Petitioners moved to dismiss the complaint on grounds of lack of cause of action, prescription, and res judicata, but the trial court denied the motion. The Court of Appeals upheld this denial.

ISSUE

Whether the trial court correctly denied the motion to dismiss the complaint filed by Mercedes P. Juntilla.

RULING

The Supreme Court granted the petition and ordered the dismissal of the complaint. The Court held that the complaint failed to state a cause of action. The property was registered solely under the name of Alipio Juntilla. Under the Torrens system, the certificate of title is conclusive evidence of ownership. For Mercedes to claim a conjugal interest, she had the burden to allege and prove that the property was acquired during the marriage, making it presumptively conjugal. Her bare allegation of conjugality, without supporting facts regarding the time and manner of acquisition, was insufficient to overcome the indefeasibility of the registered title. Furthermore, her cause of action, if any, had prescribed. The sheriff’s sale occurred in 1958, and the certificate of sale was issued in 1959. Any action to annul the sale based on the alleged conjugal nature of the property should have been filed within four years from the issuance of that certificate, not from the 1968 ejectment. Finally, the rights of an innocent purchaser for value, A.D. Guerrero, were protected. Guerrero relied on PNB’s clean title, and the law does not oblige a buyer to look beyond the certificate of title. The Court of Appeals’ decision was annulled and the complaint was ordered dismissed.