Bishop v. Salang
REITERATIONFacts
The Antecedents: Petitioners were in possession of portions of a parcel of land totaling 1,652 square meters in Calapacuan, Subic, Zambales. The entire parcel was registered in the name of private respondents under Transfer Certificate of Title No. T-29018. Procedural History: Private respondents filed a suit for recovery of possession, invoking their rights as registered owners. Petitioners claimed the lots were part of the public domain, could not be registered, and asserted long and continuous possession, supported by tax declarations and contracts of sale or inheritance. The Regional Trial Court (RTC) ruled in favor of the private respondents, holding that as registered owners, they had the lawful right to possession. The Court of Appeals affirmed the RTC decision. The Petition: Petitioners sought reversal, arguing that the land was part of the public domain, that they acquired title by laches, and alternatively, that they should be considered builders in good faith.
Issue(s)
Whether the land in question, registered under the Torrens system, could still be considered part of the public domain. Whether petitioners acquired title to their respective lots by laches. Whether petitioners should be considered builders in good faith entitled to rights under Articles 448, 546, 547, and 548 of the Civil Code.
Ruling
The petition is denied. The Court affirmed the decisions of the lower courts, upholding the indefeasibility of the Torrens title and the registered owners' right to recover possession.
Ratio Decidendi
On the issue of the land being part of the public domain: The Court held that the private respondents' title was traceable to an Original Certificate of Title issued in 1910, which was incontrovertible and conclusive against the whole world. The presumption of regularity applied to its issuance, covering the finding that the land was private and registrable. A certification from the Bureau of Forestry that the land was alienable and disposable public land deserved scant consideration as it lacked legal basis and could not prevail against a court decision declaring the land registrable. Furthermore, no opposition was entered by the Director of Forestry during the land registration proceedings. An action to annul a Torrens certificate for being void ab initio requires proof of lack of jurisdiction or actual fraud, and the one-year prescriptive period for fraud had long expired. On the issue of acquiring title by laches: The Court reiterated that as registered owners, private respondents had an imprescriptible right to eject any person illegally occupying their property. This right is never barred by laches, regardless of the length of unauthorized or tolerated possession. The petitioners' contention that they acquired title by laches was essentially an assertion of acquisitive prescription, which cannot ripen into ownership over land registered under the Torrens system. The purpose of the Torrens system is to quiet title and make registered owners secure, preventing loss of land through prescription. On the issue of being builders in good faith: The Court ruled that petitioners could not invoke the status of builders in good faith because they knew from the outset that they had no right to occupy the lots. They insisted the land was public domain and did not verify the registration, which served as constructive notice to the whole world. Their entry onto the land without permission or authority made them squatters, negating any claim of good faith.
Main Doctrine
The Torrens system provides indefeasible titles, and registered owners cannot lose their property through prescription or laches, even if others possess and build on it in good faith, as long as the possession is unauthorized.