Collado v. Court of Appeals
REITERATIONFacts
The Antecedents: Spouses Pedro Aventura and Anacleta Galan were issued Original Certificate of Title No. G-153 for two lots. They subsequently sold these lots to spouses Jose E. Collado and Aurora Provido for P4,000.00. Prior to the sale, Collado was shown the title, which appeared free from liens and encumbrances, and the cadastral decision adjudicating the lots to the Aventura spouses. Collado also visited the lands and saw Nicomedes Copiat, whom Anacleta Galan identified as a tenant. Collado proceeded with the purchase, and a new title was issued in his and his wife's names. Three months later, Collado discovered that other persons claimed ownership of the lands. Procedural History: Collado and his wife filed an action before the Court of First Instance (CFI) of Iloilo seeking to be declared owners with the right of possession and for damages. The CFI ruled in favor of the Collados. However, the Court of Appeals (CA) reversed the CFI decision, declaring the registration decree and the subsequent transfer certificate of title null and void. The CA ordered the cadastral court to give due course to the answers filed by Nicomedes Copiat, et al., in the cadastral case and to render a decision after hearing evidence. The Petition: Petitioners Collado et al. sought review of the CA decision, arguing that the CA erred in holding them purchasers in bad faith and in nullifying the decree of registration and title, invoking the principle against collateral attack.
Issue(s)
Whether the Court of Appeals erred in holding that the petitioners acted in bad faith in purchasing the lands. Whether the Court of Appeals erred in nullifying the decree of registration entered in the cadastral case and the subsequent certificate of title. Whether the petition for review filed by the respondents constituted a collateral attack on the decree of registration.
Ruling
The Supreme Court affirmed the decision of the Court of Appeals, holding that the petitioners were not purchasers in good faith and that the attack on the decree of registration was not collateral but a proper petition for review filed within the reglementary period. The Court declared the registration decree and the transfer certificate of title null and void and ordered the cadastral court to proceed with the hearing of the petition for review.
Ratio Decidendi
On the issue of bad faith: The Court upheld the findings of the Court of Appeals that the petitioners acted in bad faith. The CA noted that Jose Collado, accompanied by policemen, visited the lands in November 1951 and was aware of the defendants-appellants cultivating the lands, seeing their plantings, houses, and families. Despite being told that the lands belonged to the Copiats and not to the Aventuras, Collado proceeded with the purchase. This awareness of a conflicting claim of possession and ownership prior to the sale negated the claim of being a purchaser in good faith. The Court emphasized that these findings of fact by the CA are conclusive upon the Supreme Court. On the nullification of the decree of registration and title: The Court found that the respondents filed their petition for review in the cadastral case within the one-year period prescribed by Section 38 of Act 496, as amended. The record showed that the petition for review was filed on December 17, 1951, within one year from the issuance of the decree on October 20, 1951. The cadastral court had suspended the proceedings for review until the civil case (the present case) was decided. Therefore, the nullification by the CA was not an error, as it merely ordered the cadastral court to give due course to the petition for review. On whether the petition for review constituted a collateral attack: The Court agreed with the Court of Appeals that the attack made on the titles was not a collateral attack. The petitions for reopening or review of the decree of registration were presented within the cadastral case itself and within the period provided by law. The suspension of proceedings by the cadastral court until the civil case was decided did not alter the nature of the action. The civil action was filed to recover possession of the land, and the courts cannot be instruments of injustice. Therefore, the Court of Appeals did not err in declaring the nullification of the decree and title, as it was a direct attack through a proper petition for review.
Main Doctrine
A petition for review of a decree of registration filed within the one-year period prescribed by law, even if filed in a separate civil action that is suspended pending the outcome of the cadastral proceedings, does not constitute a collateral attack on the decree of registration. The cadastral court retains jurisdiction to hear and decide such petition on its merits.