G.R. No. L-46410 October 30, 1981
ERNESTO BALBIN, JOSE ORIÑA, MAURICIO NARAG, ROSA STA. MA. SYTAMCO, BASILIO SYTAMCO, LEOCADIO SYTAMCO, AMADO V. REYES, LYDIA V. REYES and APOLINARIO REYES, petitioners, vs. PEDRO C. MEDALLA and JOSEFINA MEDALLA and LINO BARBOSA, Judge of the Court of First Instance of Mamburao, Occidental Mindoro, respondents.

FACTS

The private respondents, spouses Pedro and Josefina Medalla, purchased a large parcel of agricultural land from the heirs of Juan Ladao in 1962. They subsequently filed an application for registration of title, relying on a Deed of Sale and an 1895 Informacion Posesoria (possessory information title) issued in the name of Juan Ladao. The petitioners opposed this application, asserting ownership over specific lots within the larger parcel by virtue of Homestead or Free Patent grants, for which they had already been issued Original Certificates of Title (OCTs) by the government between 1957 and 1963. The land registration court, in its 1969 decision, gave due course to the Medallas’ application but expressly reserved resolution of the petitioners’ opposition, noting the Medallas’ intention to file a separate action to cancel the petitioners’ titles. Consequently, the Medallas instituted an action for reconveyance and annulment of titles in 1973, which the trial court decided in their favor, declaring their ownership based on the ancient possessory title, nullifying the petitioners’ OCTs, and awarding damages.

ISSUE

The core issue is whether an Informacion Posesoria, by itself, constitutes superior and conclusive evidence of ownership that can override Torrens titles (OCTs) issued pursuant to Homestead or Free Patent grants.

RULING

The Supreme Court reversed the trial court’s decision and dismissed the Medallas’ complaint. The legal logic centers on the nature and evidentiary weight of an Informacion Posesoria under Philippine law. The Court clarified that a possessory information title is not a title of absolute ownership but merely a prima facie evidence of possession that requires judicial confirmation in a land registration proceeding under Act No. 496 (the Land Registration Act). For such a title to mature into one of absolute ownership, it must be accompanied by a showing of actual, public, continuous, and adverse possession for the period prescribed by law. Crucially, even if converted, it can still be lost through prescription. In this case, the Medallas failed to prove that they or their predecessors-in-interest were in actual possession of the specific nine lots occupied by the petitioners. The petitioners’ Torrens titles, issued after the government found them to be in actual possession and qualified for homestead or free patent grants, had already become indefeasible and incontrovertible one year after their issuance. Therefore, the petitioners’ titles, rooted in a state grant following an official investigation, prevail over the Medallas’ unconfirmed and unperfected claim based solely on a historical possessory information. The Court held that the petitioners possess a better right to the land.