Daclag v. Haber
REITERATIONFacts
The Antecedents: Spouses Candido and Gregoria Macahilig owned seven parcels of land. Their daughter, Maxima, entered into a Deed of Extra-judicial Partition with the heirs of her deceased brothers, Mario and Eusebio, concerning these lands. Parcel One, an irrigated riceland, was partitioned such that the southern half went to the heirs of Mario and the northern half to the heirs of Eusebio. Maxima executed a Statement of Conformity, acknowledging the partition and waiving her rights to the portions adjudicated to her co-heirs, despite the lands being declared in her name for taxation purposes. Subsequently, Maxima sold Parcel One to spouses Adelino and Rogelia Daclag (petitioners) via a Deed of Sale. Later, Rogelia Daclag obtained a free patent and OCT No. P-13873 for the entire Parcel One. Procedural History: The heirs of Eusebio Macahilig (respondents) filed a complaint for recovery of possession and ownership, cancellation of documents, and damages against Maxima and the Daclag spouses. They alleged they were the lawful owners of the northern half of Parcel One by virtue of the Deed of Extra-judicial Partition. Petitioners, in their defense, claimed they purchased the land in good faith and for value, and that Rogelia was the registered owner since 1984, her title being incontrovertible. Respondents amended their complaint to ask for reconveyance of the northern half of Parcel One. The Regional Trial Court (RTC) declared Maxima in default and, after trial, declared the Deed of Sale null and void, declared respondents the lawful owners of the northern half, ordered petitioners to vacate and reconvey the land, and awarded damages. The Court of Appeals (CA) affirmed the RTC decision. The Petition: Petitioners filed a Petition for Review on Certiorari with the Supreme Court, assailing the CA's decision and resolution, arguing that they had valid title, were purchasers in good faith, and that the award of damages was erroneous.
Issue(s)
Whether Maxima was the previous owner of Parcel One, including the respondents' one-half northern portion. Whether petitioners could validly invoke the defense of purchasers in good faith. Whether reconveyance is the proper remedy.
Ruling
The Supreme Court denied the petition for review and affirmed the Decision of the Court of Appeals. The Deed of Sale executed by Maxima in favor of the petitioners was declared null and void. The respondents were declared the true and lawful owners of the northern one-half portion of Parcel One and are entitled to its possession. Petitioners were ordered to vacate and deliver possession of the said portion to the respondents, and to execute a deed of reconveyance. Petitioners were also ordered to pay respondents their share in the produce of the land annually from 1984 until possession is restored.
Ratio Decidendi
On whether Maxima was the previous owner of Parcel One: The Court held that Maxima was not the owner of the northern one-half portion of Parcel One. The Deed of Extra-judicial Partition, to which Maxima affixed her thumbmark, clearly showed that this portion was adjudicated to the heirs of Eusebio Macahilig. Furthermore, Maxima executed a Statement of Conformity, also with her husband's conformity, wherein she acknowledged that the lands declared in her name were actually properties of her deceased parents and that she waived her rights to the portions adjudicated to her co-heirs. Both documents were declarations against her interest and were never questioned by Maxima or her heirs. Maxima's possession of the land was not in the concept of an owner, but rather as a tenant at the behest of her daughter, who was the tenant of the respondents. Tax declarations in Maxima's name were not conclusive proof of ownership, and her mortgaging the land did not vest ownership in her. The principle of nemo dat quod non habet (no one gives what one does not have) applies, meaning Maxima could only sell what she owned, and she did not own the northern half of Parcel One. On whether petitioners could validly invoke the defense of purchasers in good faith: The Court ruled that petitioners could not be considered purchasers in good faith. The defense of good faith is generally applicable to registered land where a buyer relies on the clean title of the registered owner. However, petitioners purchased the property when it was still unregistered land. Therefore, they bought the property at their peril. Their claim of good faith would not protect them if their seller, Maxima, did not own the property at the time of the sale. Moreover, the RTC noted that the petitioners reflected a low sale price in the Deed of Sale to avoid taxes, which is an act that should not be given protection by the courts. The fact that Rogelia obtained a free patent and title does not automatically make them owners, as a certificate of title is merely evidence of ownership and cannot be used to protect a usurper or as a shield for fraud. On whether reconveyance is the proper remedy: The Court affirmed that reconveyance is the proper remedy. An action for reconveyance aims to transfer the property or its title that has been wrongfully or erroneously registered in another person's name to its rightful owner or to the one with a better right. The Supreme Court's land registration laws do not grant a holder of a certificate of title a better title than what they actually have. The issuance of a title does not preclude the possibility that the property is co-owned or held in trust. In this case, the respondents sufficiently established their ownership of the northern half of Parcel One through the Deed of Extra-judicial Partition and Statement of Conformity, which predated petitioners' acquisition and the issuance of the free patent. The action for reconveyance was filed within the ten-year prescriptive period from the registration of the deed or issuance of the title. The award of damages for the produce of the land was also affirmed, based on the principle that owners are entitled to the fruits of their property and that no one should be unjustly enriched at the expense of another.
Main Doctrine
A seller must have the right to transfer ownership of the property sold. A deed of sale is void if the seller is not the owner of the property, and the buyer acquires no more than what the seller can legally transfer. Registration of a property under the Torrens System does not create title but merely serves as evidence of ownership, and a certificate of title cannot be used to protect a usurper or as a shield for fraud.