G.R. No. L-48074. December 14, 1978.
PON’S REALTY CORPORATION, petitioner, vs. THE HON. COURT OF APPEALS, and PRUDENCIO G. FALCIS, et al., respondents.

FACTS

Private respondent Prudencio G. Falcis, claiming to act as an “Administrator-Plenipotentiary-Extraordinary” by virtue of a questionable 1954 memorandum purportedly signed by then President Ramon Magsaysay, and as attorney-in-fact for certain heirs, filed a complaint seeking the nullification of Transfer Certificates of Title (TCTs) registered in the name of petitioner Pon’s Realty Corporation. The complaint alleged that the lands covered by these titles, derived from Original Certificates of Title (OCTs) issued as early as 1907, 1916, and 1931, were fraudulently registered and are actually part of the vast estate of Don Mariano San Pedro y Esteban covered by “Titulo de Propriedad No. 4136.” The heirs and two lot buyers joined the suit, praying for the declaration of nullity of the petitioner’s titles, recognition of their ownership, and an award of damages.
Petitioner moved to dismiss the complaint on several grounds, including lack of cause of action, lack of legal personality of Falcis to sue, prescription, laches, and the indefeasibility of the Torrens titles. The trial court denied the motion to dismiss, and the Court of Appeals sustained this denial. Pon’s Realty Corporation elevated the matter to the Supreme Court via a petition for review.

ISSUE

Whether the trial court correctly denied the motion to dismiss the complaint for quieting of title and damages filed by Prudencio G. Falcis.

RULING

No. The Supreme Court reversed the decision of the Court of Appeals and ordered the dismissal of the complaint. The ruling was anchored on multiple, independently sufficient legal grounds. First, an action to nullify Torrens titles long after their issuance is not a proper remedy. The titles in question were derived from OCTs issued, at the latest, in 1931. Under the Land Registration Act, a decree of registration becomes incontrovertible and indefeasible one year after its issuance. The action, filed decades later, is clearly barred.
Second, private respondent Falcis utterly lacked the legal personality to institute the suit. His claimed authority as an “Administrator-Plenipotentiary-Extraordinary” was based on a patently irregular and spurious document, which the Court refused to recognize. Furthermore, since the property was allegedly part of an estate under judicial administration in Bulacan (Special Proceedings No. 312-B), only the court-appointed judicial administrator, or someone specially authorized by the probate court, could file such an action.
Third, the action for damages could not prosper against the petitioner, who was a mere subsequent transferee in good faith and for value, as evidenced by annotations on the titles, and not the alleged original fraudulent registrant. Any cause of action for damages had also long prescribed. Given these fatal defects, the complaint failed to state a cause of action and was dismissible on its face.