G.R. No. L-61416 March 18, 1985
Felda Albienda, petitioner, vs. Hon. Court of Appeals, Angeles Sumagpao and Ruben Sumagpao, respondents.

FACTS

Private respondents, the Sumagpao spouses, applicants for a free patent over Lot No. 1548, filed an action against petitioner Felda Albienda for correction of title and recovery of possession. They alleged that an 8-hectare portion of their Lot 1548 was erroneously included in the technical description of Albienda’s adjoining Lot 1550, covered by TCT No. T-1718. They based their claim on a 1958 indorsement from a Bureau of Lands survey chief suggesting a possible computational mistake in the technical description of Lot 1550. The Sumagpaos traced their title to a 1968 sale, while the land was originally unregistered.
Petitioner Albienda asserted ownership derived from a registered Torrens title. Lot 1550 was originally registered in the name of Enesaria Goma on July 23, 1958, subsequently sold to Gliceria Senerpida in 1959, and then purchased by Albienda in good faith and for value in 1972. Albienda’s special defense was that an action for correction of the certificate of title was no longer available, as more than one year had elapsed since the issuance of the original certificate of title in 1958. The trial court and the Court of Appeals ruled in favor of the Sumagpaos, ordering the correction of Albienda’s title to conform to the survey return.

ISSUE

Whether the technical description in a registered certificate of title can be corrected through an ordinary action after the lapse of more than one year from its issuance, based on an alleged error in the original survey.

RULING

No. The Supreme Court reversed the decisions of the lower courts. The core legal principle is the indefeasibility of a Torrens title after the lapse of one year from the decree of registration. The original certificate of title for Lot 1550 was issued in 1958. The action filed in the 1970s sought a substantial correction that would effectively alter the area and boundaries decreed in that registration. Such an action is a collateral attack on the title, which is prohibited after the one-year period for review has expired. The Torrens system aims to provide certainty and stability to land ownership; thus, every purchaser for value and in good faith, like Albienda, can rely conclusively on the face of the certificate of title. The alleged error, stemming from a survey return, should have been contested during the registration proceedings or through a direct proceeding within the prescribed period. The proper remedy for the Sumagpaos, whose claim arose from an unregistered parcel, lies against their own predecessors-in-interest, not against a registered owner holding an indefeasible title. The Court emphasized that allowing such corrections long after registration would undermine the very essence of the Torrens system.