Miranda v. Court of Appeals
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns the ownership of a one-third (1/3) northern portion of Lot No. 581 of the Biñan Estate. The private respondents, as heirs of spouses Gabriel Alora and Tarcila Alzona, claim ownership based on a deed of sale from Melecio Legasto dated April 28, 1930, who in turn purchased it from Norberto Almoro on June 10, 1917. The petitioners, however, claim ownership through a deed of donation executed by Roberto Almoro (predecessor-in-interest of the defendants, except Pedro de la Cruz) on January 19, 1948, covering the entire Lot No. 581, and a subsequent donation of the disputed portion to Pedro de la Cruz on August 5, 1948. The private respondents assert that their predecessors-in-interest declared the disputed portion for tax purposes, fenced it, and built a small resthouse thereon. 2. Procedural History: The private respondents, as plaintiffs, filed an action for reconveyance, annulment, and damages against the petitioners and others in the Court of First Instance of Laguna. The trial court rendered a judgment on August 5, 1975, declaring the deeds of sale in favor of the Aloras valid and the deed of donation by Roberto Almoro void with respect to the disputed one-third portion. The defendants were ordered to reconvey the portion to the plaintiffs. The defendants appealed to the Court of Appeals, which affirmed the trial court's decision in toto on February 7, 1977. The Court of Appeals found that prescription had not set in, as the plaintiffs discovered the registration of the entire lot in 1961 and filed their complaint in 1968, within the ten-year prescriptive period. The appellate court also upheld the authenticity of the ancient documents and the continuous possession by the plaintiffs. 3. The Petition: The petitioners, Miguela Miranda, Felicidad de la Rosa, and Luz de Lubio, seek review on certiorari of the Court of Appeals' decision. They argue that their ownership, derived from the deed of donation and subsequent registration of the entire Lot No. 581 in their names in 1961, should prevail. The petition contends that the Court of Appeals erred in upholding the validity of the ancient deeds of sale and in finding that the action had not prescribed. The petitioners' reliance on their Torrens titles is challenged by the respondents, who argue that registration does not vest title if the registered land was not legally acquired by the registrant, especially when done in bad faith. The Supreme Court is asked to determine the legal implications of the conflicting claims and the effect of registration on prior unrecorded sales and subsequent donations.
Issue(s)
Whether the private respondents' action for reconveyance had prescribed. Whether the deeds of sale and certifications presented by the private respondents are valid and authentic. Whether the deed of donation executed by Roberto Almoro in favor of the defendants is valid with respect to the disputed one-third portion of Lot No. 581. Whether the registration of the entire Lot No. 581 under the Torrens system by the petitioners vests them with ownership over the disputed portion.
Ruling
The petition is denied. The decision of the Court of Appeals is affirmed.
Ratio Decidendi
On the issue of prescription: The Court held that the action had not prescribed. The private respondents discovered the registration of the entire Lot 581 by the defendants in 1961 and filed their complaint for reconveyance in 1968. The ten-year prescriptive period for actions based on fraud or mistake, or for reconveyance, had not yet elapsed from the time of discovery. On the validity and authenticity of the deeds: The Court upheld the authenticity and due execution of the deeds of sale, noting that they were ancient documents written on aged paper, unblemished by alterations, and bore documentary stamps from the era of the "Philippine Islands." Furthermore, the existence of tax declarations in the name of Gabriel Alora, which cancelled portions of Roberto Almoro's tax declaration for Lot 581, corroborated the private respondents' claim of ownership and possession. The Court also noted that the petitioners' attempt to assail these factual findings of the Court of Appeals must fail, as only legal issues can be raised in a petition for review under Rule 45. On the validity of the deed of donation: The Court ruled that the deed of donation executed by Roberto Almoro in favor of the defendants was void with respect to the one-third portion of Lot No. 581. This is because Roberto Almoro had already sold that specific portion to Melecio Legasto, who in turn sold it to Gabriel Alora. A donor cannot lawfully convey property that is no longer theirs. On the effect of registration under the Torrens system: The Court clarified that mere possession of a certificate of title under the Torrens system does not automatically make the holder the true owner of all the property described therein. If a person obtains a title that includes land which can no longer be registered, they do not become the owner of the illegally included lands by virtue of the certificate alone. Registration is not a mode of acquiring property and does not grant a better right than what the holder actually possesses, especially if the registration was done in bad faith. In this case, the petitioners acquired only the portion that still belonged to their donor-benefactor; the portion conveyed to them but no longer owned by the donor was impressed with a trust in favor of the true owners, the private respondents.
Main Doctrine
A deed of donation is void with respect to a portion of the property that the donor had already sold. Registration of property under the Torrens system does not vest ownership if the registration was done in bad faith or includes property that the registrant does not legally own.