Mendiola v. Sangalang
REITERATIONFacts
The Antecedents: The subject property was originally registered in the name of Honorata G. Sangalang. Honorata died intestate without issue. Petitioner Abigail Mendiola and Vilma Aquino are nieces of Honorata, while respondent Venerando P. Sangalang is Honorata's nephew. In 2003, respondent discovered that the property was registered in the names of petitioner and Vilma, purportedly by virtue of a Deed of Sale dated January 29, 1996, executed by Honorata in their favor. A new title, TCT No. N-148021, was issued in their names. In July 2003, respondent allegedly broke open a unit of the commercial building on the property and detained it. Petitioner and Vilma demanded respondent vacate, but he refused. After failed barangay conciliation, petitioner and Vilma filed an accion publiciana on October 18, 2005, seeking to recover possession of the unit and payment of reasonable rentals. Procedural History: The RTC dismissed the complaint, noting that the defense of co-ownership converted the case to accion reivindicatoria. It found that as heirs of Honorata, all parties had an equal right to the property and that the resolution of a falsification complaint against petitioner and Vilma constituted a prejudicial question. The RTC ruled that the plaintiffs failed to prove a better right of possession. The CA affirmed the dismissal, disagreeing with the conversion to accion reivindicatoria but agreeing that the plaintiffs failed to prove a better right of possession, holding that as co-owners pro indiviso, all parties had an equal right to possess. The Petition: Petitioner seeks review of the CA decision affirming the dismissal of her accion publiciana.
Issue(s)
Whether the petitioner has the better right of possession over the subject property. Whether the Deed of Sale executed by Honorata in favor of the petitioner and Vilma is valid; and whether the Torrens title issued in the names of the petitioner and Vilma is valid. On the parties' rights as co-heirs and co-owners.
Ruling
The petition is denied. The Decision of the Court of Appeals affirming the dismissal of the petitioner's accion publiciana and the award of attorney's fees in favor of the respondent is affirmed in toto.
Ratio Decidendi
On the issue of whether the petitioner has the better right of possession over the subject property: The Court affirmed the lower courts' findings that the petitioner failed to prove her better right of possession. While the petitioner and Vilma relied on their Torrens title as registered owners, the Court found this title to be void. The Deed of Sale purportedly executed by Honorata in their favor was dated January 29, 1996. However, Honorata had passed away on May 31, 1994, two years prior to the execution of the deed. This patent defect indicated that Honorata's signature on the Deed of Sale was a product of forgery, rendering the deed void and producing no civil effect. Consequently, petitioner and Vilma acquired no right under the void Deed of Sale, and their Torrens title, derived from this void instrument, was also invalid. The Court reiterated the principle that when an instrument is forged, even if accompanied by the owner's duplicate certificate of title, the registered owner does not lose title, and the assignee in the forged deed acquires no right. Therefore, the petitioner, as a purported co-owner based on a void title, could not establish a better right of possession than the respondent, who claims as a co-heir. On the validity of the Deed of Sale and the Torrens title: The Deed of Sale dated January 29, 1996, was found to be void ab initio because the purported seller, Honorata G. Sangalang, was already deceased at the time of its execution. Her signature on the deed was therefore a forgery. A void deed produces no civil effect and cannot create, modify, or extinguish any juridical relation. Consequently, the Torrens title (TCT No. N-148021) issued in the names of petitioner and Vilma, which was based on this void deed, was also void. The Court emphasized that a Torrens title does not confer ownership but merely confirms or records title already existing and vested. The indefeasibility of a Torrens title cannot be used to perpetrate fraud. Registration procured by fraud does not vest title, and the person in whose name the land is registered holds it as a mere trustee. The validity of the title could be questioned even in an accion publiciana because an action to declare the nullity of a void title does not prescribe and is susceptible to collateral attack. On the parties' rights as co-heirs and co-owners: By theory of succession, since the Deed of Sale and the resulting title were void, the title over the property remained in the name of Honorata. As such, the petitioner and the respondent, being heirs of Honorata, are co-owners of the property. As co-owners, they are equally entitled to possession thereof, either de facto or de jure. Therefore, petitioner and Vilma had no right to exclude the respondent from enjoying possession of the property through a possessory action. The RTC and CA correctly dismissed the complaint for accion publiciana because the petitioner failed to prove a better right of possession, as the respondent, as a co-heir, also had an equal right to possess the property.
Main Doctrine
A Torrens title obtained through a void deed of sale, such as one with a forged signature, does not confer any right or title to the property, and the registered owner does not lose title. Consequently, the registered owners cannot maintain an action for recovery of possession based on such void title.