G.R. No. L-9914, December 19, 1957.
CONCEPCION H. LUNA, ALFREDO HOELZL, CARMEN A. HOELZL, ELIZABETH A. HOELZL, IGNACIO A. LUNA, JUAN ALCAZAR, REYNALDA ALCAZAR, GLORIA AMPARO HUAB, FRANCISCA H. JAVIER, ANGELA A. BUENCAMINO, RUPERTO ALCAZAR, JR., and JOSE ALCAZAR, petitioners-appellants, vs. MONS. PEDRO P. SANTOS and MONS. FLAVIANO B. ARIOLA, respondents-appellees.

FACTS

Rev. Fr. Martin S. Alcazar was the original owner of two parcels of land. On February 17, 1948, he executed an absolute deed of sale in favor of the Roman Catholic Bishop of Nueva Caceres (Mons. Pedro P. Santos) for P12,000.00. The deed stipulated it should be registered under Act 3344 as the lands were not yet under the Torrens system, although registration proceedings (GLRO No. 2, Rec. No. N-728) were pending. On July 14, 1953, Original Certificate of Title No. O-32 was issued in Fr. Alcazar’s name. The deed of sale was not registered under Act 3344 as agreed. After Fr. Alcazar’s death, on January 17, 1954, the deed was presented for registration along with an instrument where Mons. Santos ceded his rights to the Roman Catholic Bishop of Legaspi (Mons. Flaviano B. Ariola). Consequently, O.C.T. No. O-32 was cancelled, and T.C.T. No. 656 was issued to Mons. Santos, which was immediately cancelled and replaced by T.C.T. No. 657 in Mons. Ariola’s name. The nephews, nieces, and alleged heirs of Fr. Alcazar filed a petition with the Court of First Instance of Sorsogon (Special Action No. 879) seeking to cancel T.C.T. No. 657 and reinstate O.C.T. No. O-32, arguing the cancellation was illegal because the deed of sale was not annotated before the original title was issued. They later argued the deed was without consideration and simulated to donate the properties to the Redemptorist Fathers. The lower court upheld the sale’s validity, finding consideration was established (P2,200.00 paid and a balance entrusted for a mission house), and dismissed the petition and respondents’ counterclaims for moral damages. Petitioners appealed.

ISSUE

Whether the lower court had jurisdiction to declare the deed of sale valid and, consequently, whether the Register of Deeds acted properly in cancelling O.C.T. No. O-32 and issuing the subsequent transfer certificates of title.

RULING

Yes. The Supreme Court affirmed the lower court’s decision. The Court held that the lower court, as a court of general jurisdiction (the Court of First Instance), had authority to pass upon the validity of the deed of sale. The petitioners themselves raised the legality of the transfers based on that instrument. Even if treated as a proceeding under Section 112 of the Land Registration Act, the court, being also a Court of First Instance, could resolve the question of the document’s validity for expediency, following precedent. The Court found no reason to reverse the lower court’s ruling that the Register of Deeds acted properly. The dismissal of the counterclaims for moral damages was also upheld, as there was no proof the petition was filed in bad faith or with malicious intent.