Tuason v. Vibat
REITERATIONFacts
1. The Antecedents: Plaintiff J. M. Tuason & Co., Inc. filed an ejectment and collection of rentals action against defendant Danny Vibat. The plaintiff claimed ownership of a parcel of land in Quezon City, alleging that Vibat unlawfully entered and constructed a house on a portion of the property without consent, causing damages at a monthly rate of P150. 2. Procedural History: Summons was allegedly served on Vibat on April 13, 1959. As Vibat failed to file a responsive pleading, the Court of First Instance of Rizal declared him in default on May 16, 1959, and subsequently rendered judgment in favor of the plaintiff on June 3, 1959. Vibat then filed a petition for relief from judgment on June 23, 1959, which was denied by the trial court. Vibat appealed this denial to the Court of Appeals, which certified the case to the Supreme Court due to the involvement of only questions of law. 3. The Petition: Appellant Vibat sought relief from the judgment, asserting that his failure to answer was not due to his fault or negligence. He claimed the person who received the summons was not a resident at his address and only delivered the documents several days after Vibat's return from a trip. Vibat argued he had valid defenses, including a purchase of the land from a third party. The Supreme Court affirmed the denial of the petition for relief, finding that Vibat lacked due diligence in discovering the default and that his alleged defense was insufficient against the plaintiff's registered Torrens title.
Issue(s)
Whether the trial court erred in denying the petition for relief from judgment. Whether the appellant had a meritorious defense against the plaintiff's claim of ownership and possession.
Ruling
The Supreme Court affirmed the denial of the petition for relief from judgment. The Court found that the appellant did not act with due diligence and lacked a meritorious defense against the plaintiff's registered Torrens title.
Ratio Decidendi
On Issue 1: The Supreme Court held that the denial of the petition for relief was proper because the appellant failed to act with due diligence. Even if Candido Calon was not authorized to receive the summons, the appellant admitted that Calon only turned over the summons several days after May 10, 1959. Had the appellant been diligent, he would have discovered the default order on May 16, 1959, and could have sought its lifting before the judgment on the merits was rendered on June 3, 1959. The failure to promptly inquire about the status of the case after receiving the summons, even belatedly, demonstrated a lack of the required diligence under Rule 38 of the Rules of Court. On Issue 2: The Supreme Court found that the appellant's alleged defense of purchasing the land from Eustaquio Alquiros, who in turn bought it from Juliana de la Cruz, was not meritorious against the plaintiff's registered Torrens title. Under Act 496, a Torrens title is conclusive as to ownership and cannot be defeated by unregistered deeds or claims of adverse possession. The Court stated that the appellant's remedy, if any, would be against his immediate vendor, Eustaquio Alquiros, based on the latter's warranty against eviction, and not against the registered owner, J. M. Tuason & Co., Inc.
Main Doctrine
The Supreme Court affirmed the denial of a petition for relief from judgment, holding that the appellant failed to demonstrate due diligence in receiving summons and did not possess a meritorious defense against the plaintiff's registered Torrens title. The Court reiterated that a Torrens title is indefeasible and cannot be overcome by unregistered claims or adverse possession, and that the remedy for a buyer whose title is thus challenged lies in an action for breach of warranty against eviction against their vendor.