Abadilla v. Obrero
REITERATIONFacts
The Antecedents: Respondents, Spouses Bonifacio and Bernabela Obrero, filed a complaint for forcible entry against petitioner Rolando S. Abadilla, Jr. They alleged that they are the registered owners of a parcel of land, evidenced by Transfer Certificate of Title (TCT) No. T-38422, issued on July 3, 2007. They claimed that on September 22, 2007, petitioner, with armed men, forcibly fenced the property, intimidated them and their customers, and destroyed improvements. Petitioner denied these allegations, asserting that he and his co-heirs are the lawful owners and possessors, having inherited the land from his father, Rolando Abadilla, Sr., who allegedly purchased it from the respondents in 1991. Petitioner claimed that respondents have repeatedly attempted to remove their fences and have surreptitiously built structures on the land. He also alleged that the respondents obtained the title through illegal means and that he purchased the land from the heirs of Ernesto Palma, who had a prior claim. Procedural History: The respondents' complaint for forcible entry was initially dismissed by the Municipal Trial Court in Cities (MTCC) of Laoag City, Branch 2. The MTCC found that respondent Bonifacio Obrero's admission of signing a 1991 Deed of Absolute Sale to Abadilla, Sr. confirmed the transfer of ownership and possession. The MTCC also deemed the case to be an acción reivindicatorÃa, over which it lacked jurisdiction. On appeal, the Regional Trial Court (RTC) of Laoag City, Branch 65, reversed the MTCC's decision. The RTC found the respondents' claim of ownership more credible, ruling that the 1991 Deed of Absolute Sale was without force and effect due to lack of consideration. The RTC ordered petitioner to vacate the premises and remove the fences. The Court of Appeals (CA) affirmed the RTC's decision, dismissing petitioner's appeal and stating that the ownership issue should be resolved in a separate proper forum. The Petition: Petitioner Rolando S. Abadilla, Jr. filed this Petition for Review on Certiorari under Rule 45 of the Rules of Court, seeking to annul the decision of the Court of Appeals. He argues that the CA erred in ruling that the issue of forum shopping was moot, in holding the unilateral 1991 Deed of Sale invalid despite respondent's acknowledgment, in disregarding the fact that respondent Bonifacio Obrero is accused of falsifying a quitclaim deed in a pending criminal case, and in disregarding decisions from other related civil cases. Petitioner contends that the CA disregarded the import of his father's possession and the respondents' alleged fraudulent acquisition of title, and that the lower courts erred in determining possession based on the respondents' TCT rather than the established facts of prior possession and sale.
Issue(s)
Whether the Court of Appeals erred in affirming the Regional Trial Court's decision which ordered the petitioner to vacate the subject land and restore possession to the respondents. Whether the 1991 Deed of Absolute Sale between the respondents and the petitioner's predecessor-in-interest was valid and perfected. Whether the respondents, as registered owners, are entitled to the possession of the subject land. Whether issues regarding the validity of a Torrens title can be raised and decided in an ejectment proceeding.
Ruling
The Supreme Court denied the petition and affirmed the decision of the Court of Appeals. The Court held that as registered owners, the respondents are entitled to the possession of the subject land. The Court found that the 1991 Deed of Absolute Sale was not perfected due to lack of consideration, as evidenced by the Land Bank check payable to a third party and the affidavit of Engineer Rodolfo Jose stating the sale did not push through. The Court reiterated that issues on the validity of a Torrens title cannot be assailed collaterally in an ejectment proceeding, which is limited to determining possession de facto. The Court found overwhelming proof of respondents' actual possession and occupation, contrasting it with petitioner's unsubstantiated claims.
Ratio Decidendi
On the entitlement to possession based on registered ownership and the preponderance of evidence regarding possession: The Court reiterated the well-settled rule that a certificate of title is evidence of indefeasible and incontrovertible title to the property, entitling the holder to possession. As the respondents are the registered owners under TCT No. T-38422, they are entitled to the possession of the subject land. This right of possession is anchored on their registered ownership, which prevails over the petitioner's claim based on an unregistered Deed of Absolute Sale. The Court emphasized that a title issued under the Torrens system is entitled to all the attributes of property ownership, including possession. Therefore, as holders of the Torrens title, the respondents are unequivocally entitled to the possession of the subject land. The Court found a preponderance of evidence favoring the respondents' claim of possession. The respondents presented overwhelming proof of actual possession and occupation, including the erection of concrete and bamboo structures for residential and business purposes, and declarations for taxation. In contrast, the petitioner's claim of possession was based on unsubstantiated affidavits of caretakers who could not definitively identify the period of repairs or trespass. The Court noted that the petitioner's alleged caretakers could not have missed the substantial improvements made by the respondents, and his failure to take more substantial legal action despite alleged reports of intrusion further weakened his claim. On the validity and perfection of the 1991 Deed of Absolute Sale: The Court agreed with the RTC and CA that the 1991 Deed of Absolute Sale was not perfected due to lack of consideration. The evidence presented, including a Land Bank check payable to Engineer Rodolfo Jose and not the supposed vendors, and the affidavit of Engineer Jose stating the sale did not push through, failed to establish a valid and consummated sale. Bonifacio Obrero's admission of his signature on the deed did not conclusively prove the respondents parted with their ownership, especially when the sale's essential elements, particularly consideration, were not sufficiently proven. The Court found the petitioner's claim of possession based on this deed to be without sufficient basis. On the nature of ejectment proceedings and the determination of possession: The Court clarified that ejectment proceedings are summary in nature, intended to provide an expeditious means of protecting actual possession or the right to possession. The sole issue is possession de facto, and title is not involved, except only for the purpose of determining possession. Where parties raise the issue of ownership, the court may pass upon it only to determine who has the better right to possess, but such adjudication is provisional. The Court found that the respondents had established their prior peaceable possession through substantial evidence, including erected structures and tax declarations, which were forcibly wrested from them by the petitioner's acts of spoliation. On the collateral attack of a Torrens title: The Court held that questions on the validity of a Torrens title are outside the jurisdiction of a trial court in ejectment proceedings. Such an attack is deemed collateral and is proscribed. The validity of a Torrens certificate of title can only be definitively resolved in a direct proceeding for cancellation of title. Therefore, the criminal case filed by Palma against respondent Bonifacio involving a Quitclaim, which the petitioner used to question the respondents' title, was immaterial to the ejectment controversy. The Court stressed that a Torrens title cannot be subjected to collateral attack; it can only be modified or altered in a direct proceeding.
Main Doctrine
As holders of a Torrens title, the respondents are entitled to possession of the subject land, and their registered ownership prevails over a mere unregistered deed of sale, especially when the perfection of the sale, including its consideration, is not sufficiently established. Issues on the validity of a Torrens title cannot be assailed collaterally in an ejectment proceeding.