Demegillo v. Lumampao
REITERATIONFacts
The Antecedents: Respondents, as heirs of Adolfo Lumampao, filed an accion publiciana against petitioner Demegillo for recovery of possession of a 3-hectare portion of Lot 3106, registered under Original Certificate of Title (OCT) No. D-4960 in their names. They alleged that Demegillo entered and tilled the land shortly before Adolfo's death, despite Adolfo's homestead application and the subsequent issuance of a Certificate of Land Ownership Award (CLOA) No. 00029958 in their names, which was registered as OCT No. D-4960. Procedural History: Demegillo filed a complaint with the Department of Agrarian Reform Adjudication Board (DARAB) seeking cancellation of the CLOA, claiming he had a 3-hectare share in Lot 3106 based on a prior agreement to subdivide the land and a subsequent transfer of rights. The DARAB dismissed his complaint, finding he lacked legal personality and a vested right. The Regional Trial Court (RTC), however, ruled in favor of Demegillo, declaring him the absolute owner of the 3-hectare portion and ordering the cancellation of OCT No. D-4960. The Court of Appeals (CA) reversed the RTC's decision, upholding the respondents' ownership and ordering Demegillo to vacate the premises. The CA denied motions for reconsideration. The DARAB, in a subsequent decision, affirmed its earlier ruling dismissing Demegillo's complaint. The Petition: Both Demegillo and Demavivas filed petitions for review on certiorari with the Supreme Court, assailing the CA's decision. Demegillo argued that the CA erred in declaring respondents as owners, in stating the RTC had no jurisdiction to order registration, and in citing a non-final DARAB decision. Demavivas sought damages and attorney's fees.
Issue(s)
Whether the Court of Appeals erred in declaring respondents as the owners of the subject lot, as allegedly settled by the DARAB, and whether the RTC had jurisdiction to order the registration of the 3-hectare portion of Lot 3106 in the name of petitioner Demegillo. Whether the Court of Appeals erred in citing the DARAB's non-final decision to the effect that petitioner Demegillo is not the real party in interest in asking for the cancellation of respondents' CLOA and title, being a mere applicant. Whether the RTC had jurisdiction to cancel a Torrens title, considering the nature of accion publiciana and ownership issues. Whether Demavivas is entitled to claims for actual, moral and exemplary damages, including litigation expenses and attorney's fees.
Ruling
The Supreme Court DENIED the Petition for Review on Certiorari in G.R. No. 211253 for lack of merit, affirming the Court of Appeals' Decision and Resolution. The Court PARTIALLY GRANTED the Petition in G.R. No. 211259, remanding the case to the Court of Appeals for further proceedings solely to determine the propriety of Concepcion L. Demavivas' claims for damages and attorney's fees.
Ratio Decidendi
On the issue of ownership, jurisdiction over CLOA/OCT cancellation, and Demegillo's claim for reconveyance: The Court affirmed the CA's ruling that Demavivas and her co-plaintiffs have a better right of possession over the disputed 3-hectare portion of Lot 3106. This is based on their ownership recognized by OCT No. D-4960, which was registered and titled in their names. The Court reiterated the principle that a person with a Torrens title over land is entitled to possession thereof. Furthermore, the CLOA and OCT, once registered, attained indefeasibility one year after issuance, becoming incontrovertible evidence of ownership. The Court emphasized that the Department of Agrarian Reform Adjudication Board (DARAB) has exclusive jurisdiction over cases involving the cancellation of CLOAs. The RTC, by ordering the cancellation of OCT No. D-4960 and adjudging Demegillo as owner of a portion, unduly arrogated unto itself the power to resolve issues that are exclusively within the DARAB's competence, thereby committing an error of jurisdiction. The RTC's action constituted a collateral attack on the Torrens title, which is prohibited except in a direct proceeding. The Court found that the RTC was without jurisdiction or power to order the reconveyance of the 3-hectare portion of Lot 3106 to Demegillo. While Demegillo's counterclaim for reconveyance was based on allegations of fraud and his continuous possession, the RTC's order to cancel the OCT and issue a new title in his favor was an impermissible collateral attack on the respondents' Torrens title, contrary to Section 48 of Presidential Decree No. 1529. Moreover, the Court held that Demegillo lacked the legal personality to file an action for reconveyance. As a mere applicant for a homestead patent and not an owner of the land, he could not be considered a real party-in-interest. The proper party to bring actions for the cancellation of a patent and title issued by the government, which would result in the reversion of the land to the public domain, is the State itself. Furthermore, the Court underscored that the November 24, 2008 Decision of the PARAD, as affirmed by the DARAB on June 4, 2013, had already attained finality. These decisions categorically dismissed Demegillo's complaint for cancellation of CLOA No. 00029958, finding that he had no vested right or interest over the property and that there was a lack of strong evidence to warrant cancellation based on fraud. The RTC's subsequent re-examination of the same evidence and assertions already considered by the DARAB, leading to a contrary conclusion, was therefore erroneous and an encroachment upon the DARAB's exclusive jurisdiction. On the finality of DARAB decisions and Demegillo's standing: The Court underscored that the November 24, 2008 Decision of the PARAD, as affirmed by the DARAB on June 4, 2013, had already attained finality. These decisions categorically dismissed Demegillo's complaint for cancellation of CLOA No. 00029958, finding that he had no vested right or interest over the property and that there was a lack of strong evidence to warrant cancellation based on fraud. The RTC's subsequent re-examination of the same evidence and assertions already considered by the DARAB, leading to a contrary conclusion, was therefore erroneous and an encroachment upon the DARAB's exclusive jurisdiction. On the nature of accion publiciana and ownership issues: The Court clarified that while an accion publiciana primarily concerns the better right of possession independently of title, courts may pass upon the issue of ownership when raised by the parties to determine who has the right to possess. However, this does not grant the RTC jurisdiction to cancel a Torrens title, which is a matter exclusively for the DARAB in cases involving agrarian reform. On Demavivas' claims for damages: The Court found that the issue of whether Demavivas is entitled to actual, moral, and exemplary damages, including litigation expenses and attorney's fees, involves questions of fact that necessitate a review of evidence. Since this issue was not squarely resolved by the CA, the Court remanded the case to the CA for further proceedings to determine the propriety and amount of these claims.
Main Doctrine
The Court of Appeals did not err in reversing the Regional Trial Court's decision, upholding the indefeasibility of the Certificate of Land Ownership Award (CLOA) and Original Certificate of Title (OCT) issued to respondents, and affirming that the Regional Trial Court lacked jurisdiction to order the cancellation of the title and reconveyance of the property, as such matters fall under the exclusive jurisdiction of the Department of Agrarian Reform Adjudication Board (DARAB).