Caraan v. Cosme
REITERATIONFacts
The Antecedents: Private respondents-spouses Salcedo R. Cosme and Nora Linda S. Cosme filed an accion reivindicatoria against Dionisio Caraan, alleging they are the registered owners of a property located at No. 65 Commodore St., Veterans Subdivision, Quezon City, under TCT No. 214949. They discovered Caraan occupying the land and had built a house thereon without their consent. Despite demands to vacate, Caraan refused. Procedural History: The Regional Trial Court (RTC) ruled in favor of the private respondents, ordering Caraan to vacate the premises, pay damages, and attorney's fees. The Court of Appeals (CA) affirmed the RTC's order to vacate but deleted the awards for damages and attorney's fees. Dionisio Caraan died during the pendency of the case, and his heirs were substituted as petitioners. The Petition: Petitioners (heirs of Dionisio Caraan) argued that the private respondents' title was derived from spurious titles (OCT No. 614 and TCT No. 3548) which were declared null and void. They claimed Caraan had a better right due to over thirty years of open, public, adverse, continuous, and uninterrupted possession in the concept of owner, and that the land was unclassified public land. Private respondents countered that a certificate of title cannot be collaterally attacked.
Issue(s)
Whether the validity of the private respondents' Transfer Certificate of Title (TCT) No. 214949 can be assailed in an action for recovery of possession. Whether petitioners' claim of acquisitive prescription over the subject property is tenable. Whether the admission of a photocopy of TCT No. RT-71061 (214949) into evidence was proper.
Ruling
The petition is denied for lack of merit. The Decision of the Court of Appeals is affirmed.
Ratio Decidendi
On the issue of collateral attack on the title: The Court reiterated the principle that a certificate of title serves as evidence of an indefeasible title. Petitioners' attempt to question the validity of TCT No. 214949 by alleging it was derived from spurious titles and that the land was unclassified public land constitutes a collateral attack. Section 48 of P.D. No. 1529 explicitly states that a certificate of title shall not be subject to collateral attack and can only be altered, modified, or cancelled in a direct proceeding. The action for recovery of possession filed by the private respondents is not the proper venue to assail the validity of the title. Therefore, the Court cannot resolve the issue of the alleged invalidity of the private respondents' certificate of title in this case. The claim that the land could not have been titled because it was unclassified public land also requires a direct proceeding to assail the title's validity. On the claim of acquisitive prescription: The Court held that claims of acquisitive prescription are unavailing on registered lands. Section 47 of P.D. No. 1529 provides that no title to registered land in derogation of the title of the registered owner shall be acquired by prescription or adverse possession. This is in line with Article 1126 of the Civil Code, which states that prescription of ownership of lands registered under the Land Registration Act shall be governed by special laws. Therefore, petitioners' alleged uninterrupted possession for 30 years cannot prevail over the private respondents' certificate of title, which is the best proof of ownership. Registered owners are entitled to possession from the time their title is issued. On the admissibility of the photocopy of the title: The Court found the admission of the photocopy of TCT No. RT-71061 (214949) to be proper. The private respondents presented the original in open court, and counsel for the petitioners stipulated that the photocopy was a faithful reproduction of the original. Furthermore, no objection was raised by the petitioners' counsel regarding the photocopy at the time of its offer as evidence. Established doctrine dictates that failure to interpose a timely objection to evidence waives the right to object. The admission of the photocopy was therefore correct, especially considering the stipulation and the lack of objection, which constituted a waiver.
Main Doctrine
A certificate of title registered under the Torrens system cannot be collaterally attacked. Claims of acquisitive prescription are unavailing on registered lands. The validity of a title can only be assailed in a direct proceeding for its cancellation.