Cervantes v. Court of Appeals
REITERATIONFacts
The Antecedents: Private respondents, as heirs of the late Antonio G. Francisco, filed an action for recovery of land with damages against petitioners. They alleged that Antonio G. Francisco was the registered owner of a parcel of land (Parcel 1, Lot No. 1, plan Psu-131830) covered by TCT No. 2200-Pangasinan. They discovered that petitioners were illegally occupying portions of this property and had declared them under their names. Petitioners Antonio Cervantes and spouses Armando Abad and Adoracion Orduña claimed ownership based on their respective alleged inheritances and purchases from predecessors-in-interest, asserting long-standing possession and improvements made on the land. They also questioned the authenticity and integrity of TCT No. 2200, alleging fraud and bad faith in its registration. Procedural History: The Regional Trial Court (RTC) of Pangasinan ruled in favor of the private respondents, declaring them owners of the land and ordering petitioners to vacate and pay damages. The RTC found that the sale to petitioners' predecessors-in-interest occurred when the property was already registered under TCT No. 2200 in the name of Antonio Francisco, rendering the subsequent sales invalid. The Court of Appeals affirmed the RTC decision in toto. Petitioners' motion for reconsideration was denied. The Petition: Petitioners sought review of the Court of Appeals' decision, arguing that the appellate court erred in concluding that private respondents were lawful owners based on a doubtful and mutilated entry in TCT No. 2200, in failing to consider subsequent acts of the parties, and in not recognizing petitioners as lawful owners of their respective lots.
Issue(s)
Whether the Court of Appeals erred in concluding that the private respondents are the lawful owners of the lands in question based on a doubtful and mutilated entry in TCT No. 2200. Whether the Court of Appeals erred in not considering subsequent acts of the parties after the sale to ascertain the identity of the land subject of the sale; and whether the Court of Appeals erred in not recognizing the defendants, herein petitioners, as lawful owners of their respective residential lots. Whether prescription and laches can be raised against the private respondents. Whether the parties are entitled to damages as claimed in their respective pleadings.
Ruling
The petition is DENIED for lack of merit. The assailed Decision of the Court of Appeals and its Resolution denying the motion for reconsideration are AFFIRMED.
Ratio Decidendi
On the ownership of the lands in question and the authenticity and integrity of TCT No. 2200: The Court affirmed the findings of the lower courts that the private respondents are the lawful owners of the parcels of land. The primary basis for this conclusion is TCT No. 2200, registered in the name of Antonio Francisco, the predecessor-in-interest of the private respondents. The Court found that the sale to petitioners' predecessor-in-interest, Tranquilino Cervantes, occurred on January 22, 1947, more than twenty-two years after TCT No. 2200 was issued on November 8, 1924. This clearly indicated that Juan Abad, who sold the land to Tranquilino Cervantes, did not own the parcel at the time of the sale, as it already belonged to Antonio Francisco. The principle that one cannot sell what he does not own, especially when the subject is titled land, was applied. Furthermore, the alleged purchases by the defendants-spouses Abad from their predecessors-in-interest were found to be unproven and insufficient to establish their right over the parcel. The Deed of Extra-Judicial Partition and the Deed of Absolute Sale presented by the Abads were deemed to have no probative value as they pertained to property already covered by TCT No. 2200 and thus did not belong to their predecessor, Juan Abad. The Court noted that the petitioners did not raise the issue of the authenticity of TCT No. 2200 during the pre-trial or trial. Issues not raised in the lower courts cannot be raised for the first time on appeal. Moreover, petitioners did not object to the formal offer of TCT No. 2200 as evidence, thereby waiving any objection to its admissibility. Even with the alleged mutilation, an examination of related exhibits showed that the sale to Vicente Espino, the alleged predecessor-in-interest of the Abad spouses, did not involve the parcel of land in dispute. The Court reiterated that a certificate of title serves as evidence of an indefeasible and incontrovertible title, which cannot be defeated by adverse possession or prescription. On the claim of lawful ownership by petitioners: The Court found the petitioners' arguments to be without merit. Their claim of ownership based on tax declarations and tax receipts was rejected, as these are not conclusive evidence of ownership. The fundamental principle that a Torrens Title is indefeasible and incontrovertible was emphasized. The trial court's finding that petitioner Cervantes had no right to the parcel he occupied was upheld because the sale to his father occurred when the land was already titled in the name of Antonio Francisco. Similarly, the Abad spouses' claims were unsubstantiated by sufficient documentary evidence, and their alleged purchases were of property already registered under TCT No. 2200. On the issue of prescription and laches: The Court agreed with the trial court that prescription and laches could not be raised against the private respondents. Instead, it was the petitioners who were found to be guilty of laches for failing to obtain a title over the parcels in question for a considerable period. The indefeasibility of a Torrens Title means it cannot be defeated by prescription or adverse possession. On damages: The trial court awarded actual damages in the amount of P4,000.00 for reasonable attorney's fees and P10,000.00 for moral damages, plus costs. The Court of Appeals affirmed this award in toto. The Supreme Court, in affirming the appellate court's decision, implicitly upheld these awards.
Main Doctrine
A certificate of title registered under the Torrens System serves as evidence of an indefeasible and incontrovertible title to the property. It cannot be defeated by adverse, open, and notorious possession, nor by prescription. Tax declarations and tax receipts are not conclusive evidence of ownership.