Demasiado v. Velasco
REITERATIONFacts
The Antecedents: Plaintiff Melquiades Demasiado claimed ownership of Lot 5169 based on a Deed of Sale with Right to Repurchase (Exhibit B) dated May 3, 1955, and a Deed of Definite Sale (Exhibit C) dated May 14, 1966, both from his uncle, Ambrosio Demasiado. Plaintiff alleged that Ambrosio Demasiado had acquired the land in 1936 from Pablo Britanico, who in turn acquired it from Feliciano Aplasca. Plaintiff stated he had been living in Silay City since 1963, during which time Ambrosio Demasiado possessed the land. Upon visiting the land after the definite sale in 1966, plaintiff found defendant Ramon Velasco working on the southern portion and asked him to stop, but Velasco did not respond. Plaintiff filed the instant case for recovery of possession. Procedural History: The Court of First Instance of Iloilo dismissed plaintiff's action for recovery of possession and also dismissed defendant's counterclaim. The intervenors' appeal record was not elevated, but they filed a motion to join the appellant's record, and their brief was answered by the appellant. The Petition: Plaintiff-appellant Melquiades Demasiado appealed the decision of the Court of First Instance, assigning two errors: (1) the trial court erred in giving probative value to the Torrens Title (Exhibit 6) after initially not admitting it, and (2) the trial court erred in denying probative value to the unregistered deeds of sale (Exhibits B and C) and dismissing the complaint.
Issue(s)
Whether the trial court erred in admitting Exhibit 6 (Original Certificate of Title) as evidence. Whether the trial court erred in denying probative value to Exhibits B and C (unregistered deeds of sale). Whether the plaintiff proved his clear right over the entire Lot 5169. Whether the intervenors have a valid claim for legal redemption.
Ruling
The Supreme Court affirmed the decision of the Court of First Instance, dismissing the plaintiff's complaint and the defendants' counterclaim. The Court held that the plaintiff failed to prove his clear right over the entire Lot 5169, and that unregistered deeds of sale cannot prevail over a valid Original Certificate of Title.
Ratio Decidendi
On the admissibility and probative value of Exhibit 6 (Original Certificate of Title): The Court held that under Section 47 of Act 496 (Land Registration Act), a certificate of title covering registered land is admissible in evidence and is conclusive as to all matters contained therein, including the identity of the owner. The Court found that the trial court's ruling to admit the certificate of title, despite an initial objection and ruling, constituted a reconsideration and reversal, making it properly admitted. The Court emphasized that unless bad faith can be established on the part of the registered owner, the certificate of title is binding against the whole world. The plaintiff's claim, based on unregistered documents, could not overthrow the existence of a valid Original Certificate of Title. On the probative value of Exhibits B and C (unregistered deeds of sale): The Court found that Exhibits B and C, being unregistered deeds of sale, could not be superior to the existing valid Original Certificate of Title (Exhibit 6). The Court noted that the description in Exhibit B indicated the parties knew the land was titled, and Exhibit C's statement about prior acquisition should have prompted inquiry into the original deed. The Court reiterated that no title to registered land in derogation to that of the registered owner can be acquired by prescription or adverse possession, as provided in Section 46 of the Land Registration Act. The plaintiff's claim anchored on these unregistered documents and the supposed possession of Ambrosio Demasiado was insufficient to establish a clear right over the entire lot. On the plaintiff's proof of clear right over the entire Lot 5169: The Court concluded that the plaintiff had not proven a clear right over the whole lot. The evidence presented by the defendants, particularly the testimony of Asuncion Aplasca, indicated that only a portion of the land was mortgaged to Ambrosio Demasiado, from whom the plaintiff derived his right. Therefore, Ambrosio could not have acquired the whole lot and consequently could not have transferred more than what he acquired to the plaintiff. The Court also noted that defendant Ramon Velasco persisted in his possession of the southern portion despite previous legal actions. On the intervenors' claim for legal redemption: The Court found that the right of legal redemption, as provided by Article 1623 of the New Civil Code, on the part of Asuncion Aplasca, Tarcila Moralidad, and Lolita Moralidad had long expired. The intervenors had long known that the other half of the land was possessed and acquired by the plaintiff's predecessor in interest, Ambrosio Demasiado, and subsequently by the plaintiff. The Court also noted that the lower court had held the period for redemption to have expired, and the intervenors failed to show otherwise.
Main Doctrine
A registered Original Certificate of Title is conclusive as to ownership and cannot be overthrown by unregistered deeds of sale or claims of prior acquisition, absent proof of bad faith or fraud in its issuance. Unregistered deeds of sale are inferior to a valid certificate of title.