Reyes v. Reyes
REITERATIONFacts
1. The Antecedents: Mateo H. Reyes and Juan H. Reyes, along with their brother Francisco H. Reyes, are registered co-owners of several parcels of land in Ilocos Norte, evidenced by Original Certificates of Title Nos. 22161 and 8066. Mateo Raval Reyes claims to have acquired Francisco H. Reyes's undivided one-third share in the lots covered by Original Certificate of Title No. 8066 through an unrecorded absolute sale. 2. Procedural History: The petitioners, Mateo H. Reyes and Juan H. Reyes, initially sought a writ of possession for all lots covered by both titles. The respondent, Mateo Raval Reyes, opposed this, asserting his claim to Francisco's share. The trial court initially granted the writ of possession, later amended to include all lots, an order from which the respondent did not appeal. Subsequently, the petitioners filed an ordinary civil action (Civil Case No. 3659) to recover products and damages from the disputed lots. The respondent counterclaimed for partition of these lots, reiterating his claim of co-ownership. The petitioners then moved to compel the respondent to surrender the owners' duplicate titles, which the trial court denied, reasoning that the lots were subject to litigation in Civil Case No. 3659. This denial and the subsequent refusal to reconsider led to the present appeal. 3. The Petition: The petitioners-appellants are before the Supreme Court via a direct appeal on a pure question of law, challenging the trial court's order denying their motion to compel the surrender of the owners' duplicate certificates of title. They argue that the subject of Civil Case No. 3659 is the products and damages, not the lots themselves, and that the respondent is barred by res judicata from raising ownership issues already decided in the writ of possession proceedings. They contend that as registered owners, they have a superior right to the possession of the duplicate titles, especially since the respondent has an independent action (his counterclaim) to assert his alleged rights.
Issue(s)
Whether the lots covered by the certificates of title are subjects of litigation in Civil Case No. 3659. Whether respondent Mateo Raval Reyes is barred by res judicata from raising the issue of ownership and possession of the undivided one-third (1/3) share of Francisco H. Reyes. Whether petitioners-appellants have a better right to the possession or custody of the disputed owners' duplicates of certificates of title.
Ruling
The Supreme Court reversed the orders of the trial court and ordered respondent Mateo Raval Reyes to deliver the owner's duplicates of Original Certificates of Title Nos. 22161 and 8066 to the petitioners.
Ratio Decidendi
On whether the lots are subjects of litigation in Civil Case No. 3659: While the Court agreed that the disputed lots are subjects of litigation in Civil Case No. 3659 due to respondent's counterclaim for partition, it found no valid reason to withhold the custody of the owner's duplicate titles from the registered owners on this ground. The Court emphasized that the pendency of a partition suit does not divest registered owners of their right to possess their titles. On whether respondent is barred by res judicata: The Court did not directly rule on res judicata but noted that respondent had already availed of an independent civil action to recover his alleged co-owner's share by filing a counterclaim for partition in Civil Case No. 3659. This action, the Court stated, sufficiently protected his rights. Furthermore, the Court suggested that respondent could avail of the provision on notice of lis pendens to record the fact that the lots are litigated. On who has a better right to the possession or custody of the disputed owners' duplicates of certificates of title: The Court held that the registered owner of the land, in whose favor and in whose name the land is registered and inscribed in the certificate of title, has a more preferential right to the possession of the owner's duplicate certificate than one whose name does not appear in the certificate and has yet to establish his right to possession. The Court cited its ruling in El Director de Terrenos v. Abacahin, 72 Phil. 326, which stated that the owner's duplicate must be issued to and delivered to the inscribed owner. The Court found no justifiable reason for respondent to retain the custody of the owner's duplicates of certificates of title, especially since his rights are protected by his counterclaim and the possibility of filing a notice of lis pendens.
Main Doctrine
The registered owner of a land, in whose favor and in whose name the land is registered and inscribed in the certificate of title, has a more preferential right to the possession of the owner's duplicate certificate of title than one whose name does not appear in the certificate and has yet to establish his right to possession thereto. The pendency of a civil action for partition does not justify withholding the custody of the owner's duplicate title from the registered owners.