G.R. No. L-26127, L-26128, L-26129 June 28, 1974
VICTOR BENIN, ET AL., plaintiffs-appellees, vs. MARIANO SEVERO TUASON Y DE LA PAZ, ET AL., defendants. J. M. TUASON & CO., INC., defendant-appellant.

FACTS

Three groups of plaintiffs-appellees separately filed complaints for recovery of possession and damages against the defendants-appellants, primarily J.M. Tuason & Co., Inc. The plaintiffs, descendants of Sixto Benin, Bonoso Alcantara, and Candido Pili, claimed ownership over distinct agricultural parcels in Caloocan, Rizal, through inheritance and alleged open, continuous, and adverse possession since the Spanish era, supported by tax declarations and a 1933 cadastral survey claim. They asserted that in 1951, the defendant corporation, through force and intimidation, entered the properties with bulldozers and armed men, destroying improvements and dwellings of their lessees.
The defendant-appellant, J.M. Tuason & Co., Inc., anchored its claim on Original Certificate of Title (OCT) No. 735, issued in 1914 pursuant to the 1909 registration case “Tuason v. Director of Lands,” which covered the vast Santa Mesa Estate, including the disputed lands. The corporation argued that the title was indefeasible and imprescriptible, having been issued under the Torrens system, and that the plaintiffs’ action was barred by prior judgment and prescription.

ISSUE

The core issue is whether the plaintiffs-appellees, claiming ownership based on long-term possession, can successfully maintain an action for recovery of possession against the registered owner, J.M. Tuason & Co., Inc., whose title originated from a 1914 decree of registration.

RULING

The Supreme Court reversed the lower court’s decision and dismissed the complaints. The legal logic is anchored on the conclusiveness and indefeasibility of a Torrens title. OCT No. 735, issued in 1914, became final and incontrovertible one year after its issuance. The Court emphasized that a title issued under a judicial decree of registration is binding upon the whole world, and all persons, including the plaintiffs’ predecessors-in-interest, are deemed to have been notified of the registration proceedings. Consequently, any claim of ownership adverse to the registered title must be asserted within the one-year period provided by law for reopening the decree. The plaintiffs’ action, filed decades later in 1955, was barred. Their claim of possession, no matter how long, cannot prevail over a registered title that had already attained incontrovertibility. The Court further noted that the validity of OCT No. 735 had been repeatedly upheld in a line of prior decisions.