G.R. No. L-45496; May 5, 1939
THE MUNICIPAL COUNCIL OF PARAÑAQUE, RIZAL, petitioner-appellant, vs. EL MONTE DE PIEDAD Y CAJA DE AHORROS DE MANILA, PADRES REDENTORISTAS, and THE ASIATIC PETROLEUM CO. (P.I.), LTD., respondents-appellees.

FACTS

The Roman Catholic Archbishop of Manila, a corporation sole, applied for and obtained registration of three parcels of land in Parañaque, Rizal, in 1911, alleging acquisition through donation from Doña Ana Maria de Araujo for religious purposes. A decree and certificate of title were issued. The property was later transferred to El Monte de Piedad, Asiatic Petroleum Co., and Padres Redentoristas, except portions expropriated for a road. Twenty-four years later, the Municipality of Parañaque filed a petition in the same registration proceedings, seeking a declaration of escheat in its favor. It alleged the property was not truly donated but was part of a chaplaincy established in 1677 by Doña Ana Maria de Araujo, with rents funding masses; upon the death of the chaplain without heirs, the property should escheat. The Court of First Instance denied the petition, ruling it could not be entertained in the registration proceedings.

ISSUE

Whether the Municipality of Parañaque’s petition for escheat, filed twenty-four years after the issuance of the original certificate of title, can be properly entertained in the original land registration proceedings.

RULING

No. The petition was correctly denied. Under the Torrens system, a certificate of title issued binds the whole world and cuts off all prior claims and liens not noted on the title. The right to escheat, if any, existed long before the registration proceedings and, not having been asserted then, is deemed waived. Furthermore, even if the municipality’s theory of an implied trust were considered, the proper remedy is a separate action, not a petition in the registration proceedings, especially where the rights of third-party transferees (El Monte de Piedad, Asiatic Petroleum, and Padres Redentoristas) are involved. The order of the lower court is affirmed.