Cormero v. Court of Appeals
REITERATIONFacts
The Antecedents: Petitioner Victoriano A. Cormero sought to register a "Documento de Venta Absoluta" dated September 2, 1920, and an "Orden" dated September 20, 1920, evidencing his purported right over Lot 67, a parcel of land now covered by Transfer Certificate of Title No. T-25197 in the name of Oceanic Real Estate, Incorporated. Procedural History: The Register of Deeds of Tacloban City denied the registration due to the alleged spurious nature of the documents and the cancellation of the original title. The National Land Titles and Deeds Registration Administration (NLTDRA) reversed this denial in a consultation. Subsequently, Oceanic Real Estate, Inc. filed a petition for prohibition and injunction with a prayer for a Temporary Restraining Order (TRO) before the Regional Trial Court (RTC) of Palo, Leyte. The RTC issued a preliminary injunction and, in its decision dated December 10, 1990, permanently enjoined petitioner Cormero and the Register of Deeds from registering the documents, declaring them falsified and the claim barred by laches. The Court of Appeals affirmed the RTC decision in toto on April 15, 1993, and denied the motion for reconsideration. Hence, the instant petition for review on certiorari. The Petition: Petitioner faults the Court of Appeals for denying his appeal despite his alleged registrable title, for not holding the "Documento de Venta Absoluta" and "Orden" as valid and genuine, for not holding Oceanic Real Estate, Inc.'s title as spurious, and for erroneously declaring him guilty of laches.
Issue(s)
Whether the respondent Court of Appeals gravely erred in denying petitioner's appeal notwithstanding that petitioner has a registrable title over Lot 67. Whether the respondent Court of Appeals gravely erred in not holding that the "Documento de Venta Absoluta" and "Orden" dated September 20, 1920 are valid and genuine. Whether the respondent Court of Appeals gravely erred in not holding that TCT No. 25197 in the name of respondent Oceanic was spurious, hence null and void. Whether the respondent Court of Appeals gravely erred in declaring petitioner guilty of laches notwithstanding evidence to the contrary. Whether the respondent Court of Appeals gravely erred in not annulling respondent Judge's Decision dated December 10, 1990.
Ruling
The Supreme Court affirmed the decision of the Court of Appeals in toto, dismissing the petition for review on certiorari. The Court held that the "Documento de Venta Absoluta" and the "Orden" were falsified and did not transmit any right to the property. Furthermore, the claim of title was barred by laches due to the 67-year delay in asserting the right.
Ratio Decidendi
On the issue of registrable title: The core of petitioner's claim rested on the "Documento de Venta Absoluta" and the "Orden," which were found to be falsified. As these documents did not transmit any valid right to the property, petitioner could not establish a registrable title. The principle of laches further barred any claim, irrespective of the genuineness of the documents, due to the excessive delay in asserting the supposed right. On the issue of the validity/genuineness of the "Documento de Venta Absoluta" and "Orden": The Supreme Court reiterated the rule that in petitions for certiorari as a mode of appeal, only questions of law may be raised, and the Court will not re-examine the probative value of evidence. Both the trial court and the Court of Appeals unequivocally declared the two documents falsified, a finding supported by laboratory findings indicating clear erasures and superimpositions. The Court emphasized that the party producing a writing that appears to have been altered must account for the alteration under Section 32 of the Rules of Court. Since petitioner failed to explain the alterations, the documents could not be accorded credible evidence and did not transmit any right to the property. The Court found no reason to depart from the concurrent findings of the lower courts regarding the falsity of the documents. On the issue of TCT No. 25197 being spurious: The petition was anchored on a plea to review factual conclusions, which is foreclosed in a petition for certiorari. The Supreme Court does not examine or contrast the oral and documentary evidence submitted by the parties unless the findings are totally devoid of support or constitute a serious abuse of discretion. The petition did not demonstrate such circumstances, and the findings of the lower courts regarding the authenticity and genuineness of the documents were binding on the Supreme Court. On the issue of laches: The Supreme Court found no reversible error in the Court of Appeals affirming the denial of petitioner's claim on the ground of laches. Laches is defined as the failure or neglect for an unreasonable and unexplained length of time to do what could and should have been done earlier. The Court noted that petitioner and his predecessors-in-interest took 67 years before taking any action to enforce their claim of title. This inaction, counted from when Ambrocia Cormero could have asserted her right in 1922 until the assertion in 1989, was deemed inexcusable and fatal to their cause of action, consistent with previous rulings that a 20-year delay can be fatal. On the annulment of the RTC Decision: Given that the findings of the RTC regarding the falsity of the documents and the application of laches were affirmed by the Court of Appeals and found to be supported by substantial evidence, the Supreme Court saw no reversible error in the appealed decision. The concurrent findings of the lower courts on factual matters, when supported by evidence, are binding on the Supreme Court. Therefore, the RTC decision, as affirmed by the CA, was upheld.
Main Doctrine
The Supreme Court affirmed the Court of Appeals' decision enjoining the registration of documents found to be falsified and declared that the claim of title over the property was barred by laches due to an unreasonable and unexplained delay of 67 years in asserting the right.