GR L 15589; (May, 1961) (Digest)
G.R. No. L-15589; May 31, 1961
Republic of the Philippines, plaintiff-appellee, vs. Saturnino R. Aricheta, defendant-appellant.
FACTS
The Republic of the Philippines filed an ejectment suit against Saturnino Aricheta to recover a parcel of land he was occupying within the East Triangle of the Quezon Memorial Park in Diliman, Quezon City. The Republic asserted ownership based on Presidential Proclamation No. 42, which established the park, and presented Certificate of Title No. 1956 issued in the name of the People’s Homesite and Housing Corporation (PHHC), a government entity. Aricheta, an attorney, defended his possession by claiming he purchased the land in good faith from Marcelino Tiburcio, who allegedly held a Spanish grant. He presented a deed of sale and documents showing his registration of the sale under Act 3344.
ISSUE
The core issue is whether the Republic has a superior right to eject Aricheta from the land, thereby resolving questions regarding the validity of the Republic’s title, the efficacy of the presidential proclamation, and the good faith of Aricheta’s possession.
RULING
The Supreme Court affirmed the lower court’s decision, ordering Aricheta’s ejectment. The legal logic is straightforward: the Republic’s Torrens title (Certificate of Title No. 1956) is conclusive evidence of ownership and prevails over any unregistered claim. The Court found that Aricheta’s vendor, Tiburcio, had no valid title, as his own application for land registration had been previously and finally denied by the court. This denial extinguished any claim of ownership Tiburcio could convey.
Aricheta’s claim of being a possessor in good faith was rejected. As a lawyer, he was charged with knowledge that lands in the area are covered by Torrens titles, and his own deed of sale contained a clause requiring the vendor to deliver a clear title, indicating his own doubt about the validity of his vendor’s claim. His attack on the PHHC title as fraudulent was deemed a bare allegation without proof. Furthermore, the presidential proclamation converting the government-owned land into a public park was upheld as a valid exercise of executive authority. The Court dismissed the appeal as frivolous and imposed treble costs on Aricheta, emphasizing the duty of a lawyer to respect established property rights under the Torrens system.