Pico v. Salcedo
REITERATIONFacts
The Antecedents: Respondents Catalina and Urbano Salcedo (Salcedos) filed an action for recovery of possession and quieting of title against petitioners Montano and Rosita Pico (Picos) over Lot No. 1188 Cad. 392-D. The Salcedos claimed ownership of the entire lot, alleging that Catalina purchased coconut lands from the Vallescas family. They allowed the Picos to remain as tenants on a portion (first lot) with a promise to plant coconuts in lieu of rent. During a survey, Montano allegedly misrepresented that his father, Jose Pico, owned the first lot, resulting in its separate titling as Lot No. 1192 in Jose Pico's name. The Picos also claimed ownership of another portion of the Salcedos' land (second lot), alleging they bought it from Vicente Diaz. Procedural History: The Regional Trial Court (RTC) declared the Salcedos as owners of the entire Lot No. 1188 (second lot) and ordered the Picos to vacate. It declared the Picos as owners of Lot No. 1192 (first lot). Both parties appealed. The Court of Appeals (CA) affirmed the RTC decision, finding both parties estopped from questioning the regularity of the survey due to the long lapse of time before they contested ownership. The Petition: The Picos assailed the CA decision, arguing they legally acquired the second lot from Vicente Diaz and that the Salcedos fraudulently included it in Catalina's title. They contended that despite the Torrens title being imprescriptible, they could still question the registration procured by fraud.
Issue(s)
Whether the Picos can still question the Torrens title of the Salcedos over the second lot despite the lapse of time and the issuance of the title. Whether the Picos sufficiently proved their ownership of the second lot by preponderance of evidence.
Ruling
The Supreme Court denied the petition for lack of merit, affirming the decision of the Court of Appeals. The Court held that the Picos raised mere questions of fact, which are not reviewable in a petition for review on certiorari. Furthermore, even if the facts were reviewed, a registered title cannot be defeated by adverse possession, and the Picos failed to present evidence of fraudulent registration or take timely action to correct the alleged fraudulent inclusion of the second lot in Catalina's title.
Ratio Decidendi
On the issue of whether the Picos can still question the Torrens title of the Salcedos over the second lot despite the lapse of time and the issuance of the title: The Court ruled that the petition raises mere questions of fact, which are generally not subject to review in a petition for review on certiorari under Rule 45 of the Rules of Court. The Picos are asking the Court to overturn the factual findings of the RTC, as affirmed by the CA, which requires a re-evaluation of the evidence. The Court reiterated that factual findings of the trial court, when adopted and confirmed by the appellate court, are binding and conclusive. Moreover, the Court emphasized that a Torrens title, once registered, cannot be defeated by adverse possession, no matter how long. The registered title serves as notice to the world, and no one can claim ignorance of its existence. Therefore, any possession by the Picos, even if open, notorious, and continuous, could not ripen into ownership over the registered second lot. The Court also noted the Picos' failure to present evidence of fraudulent registration and their inaction to correct the alleged fraudulent inclusion of the second lot in Catalina's title since its registration in 1969. On the issue of whether the Picos sufficiently proved their ownership of the second lot by preponderance of evidence: The Court found no reason to grant the petition even if it were to review the facts. The Picos' claim of ownership was based on a deed of sale from Vicente Diaz, a "Declaracion Jurada" from Diaz, an attestation from Teodorico Plaza, and the testimony of Pociano Ajos. However, the RTC and CA did not give these pieces of evidence sufficient weight to establish ownership, especially in light of the registered title of the Salcedos. The Court highlighted that the Picos purchased the second lot in 1977, more than eight years after the land had already been registered in Catalina's name in 1969. The indefeasible nature of Torrens titles means that possession cannot defeat a registered title. The Picos' argument that they could still question the title due to fraudulent inclusion was not substantiated with evidence. The Court observed that the Picos had not filed any action to correct the alleged fraudulent registration for a considerable period, and the present case originated from the Salcedos' complaint to quiet their title.
Main Doctrine
A Torrens title, once registered, cannot be defeated by adverse possession, no matter how long, as the title is notice to the world and no one can plead ignorance of the registration. Claims of fraudulent registration must be supported by evidence and timely action to correct the title.