Garing v. Silva
REITERATIONFacts
The Antecedents: Spouses Pacifico and Dorotea Garing filed a complaint for reconveyance of property against Marcos Silva, alleging they were lawful possessors of Lot C and that accretion caused by the Mangop River formed a strip of dry land which they and their predecessors-in-interest possessed and cultivated. They claimed this accreted land was identified as Lot No. 4891-B-1 and Lot No. 4891-B-2 in a 1938 survey. Marcos Silva claimed these lots were within his property. Later, Teresita "Esing" Silva, Marcos' wife, told the Garings to stop harvesting crops from these lots. Pacifico Garing discovered the lots were included in Lot No. 4891-B, covered by Original Certificate of Title (OCT) No. P-16110 issued in Marcos Silva's name on August 5, 1969. Procedural History: During the pendency of the reconveyance case, Jose Acosta intervened, alleging he purchased the two lots from the heirs of Marcos Silva. He claimed the Garings were present during his survey and did not object. He argued the complaint had prescribed since the original registration of Lot No. 4891-B was in 1969, and the complaint was filed in 1984. The Regional Trial Court (RTC) dismissed the complaint and declared the defendants/intervenor as lawful owners. The Court of Appeals (CA) affirmed the RTC's decision, holding that the claim of accretion was not supported by evidence and that the lots were within Marcos Silva's titled property. The CA also noted that intervenor Jose Acosta had the right to rely on the face of the title. The Petition: The heirs of Pacifico Garing filed a Petition for Review on Certiorari assailing the CA's Decision and Resolution.
Issue(s)
Whether the claim of accretion is supported by evidence. Whether the intervenor, as a vendee, had the right to rely on the face of the Original Certificate of Title. Whether the complaint for reconveyance had prescribed. Whether the Supreme Court can review the factual findings of the Court of Appeals.
Ruling
The Supreme Court denied the petition and affirmed the Decision and Resolution of the Court of Appeals. The Court held that it is not a trier of facts and is limited to reviewing errors of law in a petition for review on certiorari, and that the findings of fact of the Court of Appeals are conclusive and binding.
Ratio Decidendi
On the claim of accretion: The Court affirmed the findings of the Court of Appeals that the claim by the petitioners that the land in question is not an accretion is not supported by evidence. The appellate court correctly ruled that the lots were inside Lot 4891-B of the respondent Marcos Silva, as evidenced by Original Certificate of Title No. P-16110 issued in his name. The Court emphasized that settled is the rule that the vendee has the right to rely on what appears on the face of the title, except when required to make inquiries due to a cloud on ownership. On the intervenor's right to rely on the title: The Court reiterated the principle that under the Torrens law, the Original Certificate of Title and the owner's duplicate copy are conclusive on all matters contained therein, principally as to the identity of the owner. Pre-existing claims and liens not noted on the certificate are cut off if not noted thereon, and the certificate binds the whole world. Therefore, the intervenor, Jose Acosta, had the right to rely on what appeared on the face of the title of his vendor, Marcos Silva. On prescription: While not explicitly ruled upon as a separate issue by the Supreme Court in its final disposition, the lower courts' dismissal of the complaint implicitly addressed the issue of prescription. The Court of Appeals noted that the intervenor argued the complaint had prescribed since the original registration was in 1969 and the complaint was filed in 1984. The affirmation of the lower courts' decisions, which dismissed the complaint, indicates that the claim was not found to be valid or timely. On the Supreme Court's power of review: The Court stressed that in a petition for review on certiorari under Rule 45 of the Rules of Civil Procedure, only questions of law may be raised. It is not the function of the Supreme Court to examine or evaluate the probative value of evidence presented before the lower tribunals. The findings of fact of the Court of Appeals are conclusive and binding upon the Supreme Court, and it is not its function to analyze or weigh evidence all over again, unless a recognized exception applies, which was not found to be present in this case.
Main Doctrine
The Court affirmed the appellate court's ruling that the claim of accretion was not supported by evidence, and that the intervenor, as a vendee, had the right to rely on the face of the title, which was conclusive as to the identity of the owner and the land. The Court reiterated that in a petition for review on certiorari, it is limited to reviewing errors of law, and the findings of fact of the Court of Appeals are conclusive and binding.