Degollacion v. Register of Deeds
REITERATIONFacts
The Antecedents: Petitioner Susan D. Degollacion (Susan) purchased two parcels of land from Antonio Dizon, resulting in the issuance of Transfer Certificate of Title (TCT) No. T-96011 and TCT No. T-96019 in her name. Susan later discovered that a portion of Lot No. 5766-B, covered by her TCT No. T-96019, was also covered by TCT No. T-26877 in the name of respondent Pilar Development Corporation (the corporation). Susan alleged that the corporation's title was derived from spurious sources and filed a complaint for cancellation of title with damages. Procedural History: The corporation filed a Motion to Dismiss, citing lack of verification, absence of a non-forum shopping certification, and non-attachment of annexes. The trial court denied the motion but directed Susan to furnish the missing annexes, a directive Susan failed to comply with. The trial court subsequently declared the corporation in default and allowed Susan to present evidence ex parte. However, the trial court dismissed Susan's complaint, finding that she failed to adequately show the corporation's title was spurious and entertaining doubts about the alleged loss of her Deed of Sale. Susan's motion for reconsideration was expunged due to non-compliance with substitution of counsel requirements. The Court of Appeals affirmed the trial court's decision. Susan appealed to the Supreme Court. The Petition: Susan contended that the Court of Appeals gravely erred in ignoring, rejecting, and/or failing to consider and appreciate her documentary and testimonial evidence, which she claimed raised doubts upon the corporation's title to an extent that would alter the outcome of the case.
Issue(s)
Whether the Court of Appeals erred in affirming the trial court's dismissal of the complaint, encompassing the adequacy of Susan D. Degollacion's proof regarding the spuriousness of Pilar Development Corporation's title. Whether the presented evidence, particularly photocopies of titles and a letter-reply from the Land Registration Authority, was sufficient to establish the spuriousness of the corporation's title, considering the tracing of titles and the admissibility of evidence. Whether Susan D. Degollacion complied with the Rules of Court regarding the presentation of secondary evidence when the original Deed of Sale was unavailable.
Ruling
The petition is denied. The assailed Decision and Resolution of the Court of Appeals are affirmed.
Ratio Decidendi
On the issue of proving spurious sources and the sufficiency of evidence regarding the dismissal of the complaint: The Supreme Court held that Susan failed to adequately prove that the corporation's title was derived from spurious sources. The Court noted that the photocopy of the corporation's title (Exh. "D"), even if admissible, did not serve the purpose of establishing its spuriousness. Furthermore, the Court entertained doubts on Susan's alleged loss of the Deed of Sale covering her lot, questioning whether her own titles might have been derived from spurious sources. On the issue of tracing titles and admissibility of evidence: The Court emphasized that when two transfer certificates of title purport to include the same land, the better approach is to trace the original certificates from which they were derived. In this case, the corporation's TCT No. T-26877 was issued on November 8, 1967, while Susan's TCT No. T-96019 was issued on June 7, 1978. The Court found that Susan did not attempt to trace back from whom her predecessor-in-interest, Dizon, acquired his title and when it was issued. In contrast, the corporation painstakingly traced its title from the time Luis Pultaje allegedly purchased the lot from the government in the 1920s. The Court also found Susan's reliance on the LRA Administrator's letter-reply unavailing, as the letter itself cautioned that the registration was without prejudice to any action attacking the validity of the document or title. The Court further pointed out that Susan failed to present the alleged spurious titles of Cristina Caro and Leonilo and Roberto Javier, which she claimed were the bases for the corporation's title, and that these annexes were not even furnished to the corporation despite court order. On the issue of compliance with the Rules of Court regarding secondary evidence: The Court highlighted Susan's failure to comply with the Rules of Court regarding the presentation of secondary evidence when the original document (Deed of Sale) is unavailable, such as procuring a certified true copy or presenting witnesses who could testify on its contents.
Main Doctrine
When two transfer certificates of title purport to include the same land, whether wholly or partly, the better approach is to trace the original certificates from which the certificates of title were derived. If only one common original certificate of title exists, the transfer certificate issued on an earlier date along the line must prevail, absent any anomaly or irregularity.