G.R. No. 78290 -94 May 23, 1989
NATALIA REALTY CORPORATION, plaintiff-appellee, vs. PROTACIO RANCHU VALLEZ, CEFERINO MARTINEZ, PABLO ESPEMEDA, AUGUSTO ARIZOLA and CERIACO BANDOC, defendants-appellants.

FACTS

Natalia Realty Corporation filed five consolidated complaints for ejectment against the appellants, alleging they unlawfully occupied portions of its land registered under Transfer Certificates of Title. The corporation prayed for their eviction and payment of compensation. In their consolidated answer, the appellants sought dismissal, arguing lack of jurisdiction and claiming ownership through long possession of over thirty years. They asserted that the plaintiff’s titles were void and should be cancelled, contending their occupancy was justified under the land reform program of P.D. No. 2. The trial court denied their motion to dismiss. The plaintiff then moved for a summary judgment, contending no genuine issue of material fact existed, as the defenses were sham, and attached an affidavit from its executive vice-president.
The trial court granted the motion for summary judgment, ordering the appellants to vacate the land, remove improvements, and pay monthly rentals. It found the appellants’ defenses—relying on long possession, the alleged nullity of the titles, and P.D. No. 2—raised no valid factual issues but mere legal conclusions insufficient to warrant a trial. The appellants appealed, and the Court of Appeals certified the case to the Supreme Court, finding it presented solely a question of law regarding the propriety of the summary judgment.

ISSUE

Whether the trial court correctly rendered a summary judgment in favor of Natalia Realty Corporation.

RULING

Yes, the Supreme Court affirmed the summary judgment. A summary judgment is proper under Rule 34 when, based on the pleadings, affidavits, and admissions, no genuine issue as to any material fact exists and the moving party is entitled to judgment as a matter of law. Its purpose is to expedite cases by weeding out sham claims or defenses. The Court examined the record and found the appellants’ defenses legally insufficient to create a triable issue. Their claim attacking the validity of the registered titles constituted a collateral attack, which is prohibited by law; a certificate of title can only be challenged in a direct proceeding. Their claim of acquisitive prescription was baseless because, under the Property Registration Decree, no title to registered land can be acquired by prescription or adverse possession against the registered owner. Finally, their reliance on P.D. No. 2 was misplaced, as nothing in that decree granted them ownership. Since the material facts regarding the plaintiff’s registered ownership were undisputed and the defenses raised pure questions of law without contesting the factual basis of the complaint, the trial court correctly determined there was no genuine issue requiring a full trial. The summary judgment was therefore valid.