Ong v. Cabucos
REITERATIONFacts
The Antecedents: Spouses Pedro and Josefa Quiamco owned a residential lot and house. After their deaths, their six children executed an Extra-Judicial Declaration of Heirs with a Deed of Donation, transferring the property to their sister, Trinidad Quiamco. Trinidad subsequently allowed her deceased brother Darius's widow, Elizabeth Quiamco, and their children (petitioners Evelyn Ong, Josephine Rejollo, and Eleonor Ortega) to occupy the property. Later, Trinidad sold the property to respondents Spouses Richard and Nilda Cabucos, who obtained a new title. Procedural History: Upon purchasing the property, the Cabucos spouses demanded that the petitioners vacate. After failing to reach a settlement at the barangay level, the Cabucos filed four complaints for illegal detainer against the petitioners. The Municipal Trial Court ruled in favor of the Cabucos, ordering the petitioners to vacate and pay rentals and fees. This decision was affirmed by the Regional Trial Court, and subsequently by the Court of Appeals. The Court of Appeals denied the petitioners' motion for reconsideration. The Petition: Petitioners filed a petition for certiorari under Rule 65 of the Rules of Court, alleging grave abuse of discretion by the Court of Appeals. They argued they had acquired ownership through acquisitive prescription and donation. However, the Supreme Court noted that the petition was filed after the period for appeal had expired, and certiorari is not a substitute for a lost appeal. Furthermore, the Court found no reason to deviate from the lower courts' findings, emphasizing that prescription does not run against registered land and that the validity of a Torrens title cannot be attacked collaterally in an illegal detainer case.
Issue(s)
Whether petitioners acquired ownership of the subject property by acquisitive prescription. Whether petitioners acquired ownership of the subject property by donation. Whether the petition for certiorari is the proper remedy given that the period to appeal had already expired. Whether prescription runs against registered land. Whether the validity of a Torrens title can be assailed in an illegal detainer case. On the right to possess.
Ruling
The petition is DISMISSED. The Decision of the Court of Appeals affirming the RTC and MTC decisions is AFFIRMED. Petitioners, their relatives, and all persons claiming rights thereto and title under them are ordered to vacate the premises, pay P500.00 monthly rental from May 15, 1995, P5,000.00 as attorney's fees, P1,000.00 as litigation expenses, and costs.
Ratio Decidendi
On acquisitive prescription: The Court reiterated the established principle that prescription does not run against registered land. A Torrens title, once registered, cannot be defeated even by adverse, open, and notorious possession. The subject property was duly registered under the Torrens system, first in the names of the original owners, then transferred to Trinidad Quiamco, and finally to the respondent-spouses Cabucos. Petitioners' claim of possession, however long, cannot extinguish the registered title of the respondents. On the claim of donation: The petitioners' claim of a verbal donation in 1972 was unsubstantiated and could not prevail against the registered title of the respondents. The Extra-Judicial Declaration of Heirs with a Deed of Donation executed by the other siblings in favor of Trinidad Quiamco, which led to the issuance of TCT No. 93046, was a valid transfer of title. The subsequent sale to the Cabucos spouses further strengthened their claim as registered owners. On the propriety of the remedy: The Court held that certiorari under Rule 65 is not a substitute for a lost appeal. Petitioners received the CA's Resolution denying their motion for reconsideration on January 28, 2000, giving them until February 12, 2000, to appeal to the Supreme Court. However, they filed their petition for certiorari on February 21, 2000, after the appeal period had expired. This procedural misstep alone warrants the dismissal of the petition, as it was clearly an attempt to circumvent the rules on appeals. On acquisitive prescription against registered land: The Court reiterated the established principle that prescription does not run against registered land. A Torrens title, once registered, cannot be defeated even by adverse, open, and notorious possession. The subject property was duly registered under the Torrens system, first in the names of the original owners, then transferred to Trinidad Quiamco, and finally to the respondent-spouses Cabucos. Petitioners' claim of possession, however long, cannot extinguish the registered title of the respondents. On the validity of the Torrens title: The Court affirmed that petitioners' assertion of ownership by donation was an attempt to assail the title of the respondents. It correctly invoked the ruling that a Torrens title cannot be collaterally attacked. The issue of its validity can only be raised in an action expressly instituted for that purpose, which was not the case in the illegal detainer proceedings. The respondents' title, evidenced by TCT No. 130676, was presumed valid and could not be impugned in the present action. On the right to possess: Having failed to establish any valid right to possess the subject property, either through donation or acquisitive prescription, the petitioners were deemed to be unlawfully withholding possession. Consequently, they were obligated to surrender possession to the respondents, who were the rightful owners as evidenced by their registered title.
Main Doctrine
Prescription does not run against registered land, and a Torrens title cannot be collaterally attacked; the issue on its validity can only be raised in an action expressly instituted for that purpose.