G.R. No. L-2116

FACTS:
Plaintiffs-appellants Bernardino Cacnio and Severino de la Cruz filed an action in the Court of First Instance against defendant-appellee Lazaro Baens. They sought to be declared the absolute owners of their respective building lots in Tambobong, which they claimed to have acquired by inheritance from their parents who had been in possession for over forty years. This action was initiated after Baens had previously sued them for ejectment in the justice of the peace court and obtained a favorable judgment. The plaintiffs also prayed for a preliminary injunction to halt the ejectment proceedings, which was granted. In his defense, Baens presented a title deed (patent) issued by the Direccion General de Administracion Civil on October 25, 1891, showing he acquired the larger tract encompassing the disputed lots through composition with the Spanish Government. This deed was duly recorded in the Registry of Property on November 14, 1891. The Court of First Instance ruled in favor of Baens, dismissing the complaint and vacating the injunction. The plaintiffs appealed.

ISSUE:
Whether the defendant-appellee’s registered title, acquired through composition with the government, prevails over the plaintiffs-appellants’ claim of ownership based on alleged inheritance and long-term possession.

RULING:
Yes. The Supreme Court affirmed the lower court’s judgment. The registered title of the defendant, evidenced by a public instrument (the government-issued patent) duly recorded under the Mortgage Law, constitutes conclusive evidence of ownership and prevails over the unregistered claim of the plaintiffs. As third parties who did not participate in the composition proceedings, the plaintiffs are bound and prejudiced by the registered title pursuant to Article 27 of the Mortgage Law. The plaintiffs’ parol evidence of possession was insufficient to overcome the defendant’s superior registered title. Furthermore, the Court could not review the factual findings of the lower court as no proper exception was taken to the order denying the motion for a new trial, limiting the review to questions of law under Section 497 of the Code of Civil Procedure.