GR 49776; (January, 1980) (Digest)
G.R. No. L-49776 January 28, 1980
RODOLFO, ANDRELINA, NORMA, LYDIA, VIRGINIA, SONIA, ELSA, ROGELIO and RAFAEL, all surnamed ZUÑIGA, petitioners, vs. COURT OF APPEALS (First Division), FELISA CERDEÑA, MARCIANA CERDEÑA, Heirs of EUSTAQUIO CERDEÑA, Heirs of PLACIDO CERDEÑA, Heirs of ROSA CERDEÑA, and Heirs of CELESTINA CERDEÑA, respondents.
FACTS
The case originated from an application for land registration filed by Felisa Cerdeña and other heirs over a parcel of land in Meycauayan, Bulacan. They claimed ownership by inheritance from their parents, Canuto Cerdeña and Francisca Serrano. The heirs of Felix Zuñiga opposed the application, asserting superior title. They alleged that the land was originally purchased in 1919 by Felix Zuñiga and Francisca Serrano. Upon Serrano’s death, her heirs sold their inherited half-share to Felix Zuñiga in 1946, thereby consolidating full ownership in him. Upon his death, his heirs, the petitioners, became the absolute owners. During the hearing, the Cerdeña applicants moved for a handwriting examination of the 1919 and 1946 deeds presented by the Zuñiga oppositors, suspecting forgery. The trial court granted the motion and issued orders to facilitate the examination by the NBI.
ISSUE
Whether the Court of Appeals erred in ruling that the trial court, acting as a land registration court, had no jurisdiction to pass upon the question of the authenticity of the deeds of sale, which involved an issue of ownership.
RULING
The Supreme Court reversed the Court of Appeals and reinstated the trial court’s decision. The legal logic is clear: in an original land registration proceeding, the fundamental issue is precisely who has a registerable title to the land. The court’s primary duty is to determine the ownership and registrability of the claim presented. The Court of Appeals misapplied the doctrine that questions of ownership are beyond the province of a land registration court. That rule applies only to subsequent proceedings involving already registered land, such as petitions for amendment of title under Section 112 of Act No. 496 . It does not apply to the original registration proceeding itself, where the very purpose is to adjudicate ownership and confirm an imperfect title under the Public Land Law. The question of whether the deeds presented by the oppositors were forged or authentic is a vital incident directly bearing on the issue of ownership. Resolving this is essential to determining who has a better right to registration. Requiring a separate action for forgery would be contrary to judicial efficiency, leading to multiplicity of suits, delay, and increased costs. The trial court, therefore, correctly exercised its jurisdiction in ordering the examination of the documents and in ultimately deciding the issue of ownership based on the evidence.