Banguis-Tambuyat v. Balcom-Tambuyat
REITERATIONFacts
The Antecedents: Adriano M. Tambuyat (Adriano) and Wenifreda Balcom-Tambuyat (Wenifreda) were married in 1965. In 1991, Adriano purchased a 700-square meter parcel of land in Bulacan. Although the deed of sale was signed by Adriano alone as vendee, the resulting Transfer Certificate of Title (TCT) No. T-145321(M) was issued in the name of 'ADRIANO M. TAMBUYAT married to ROSARIO E. BANGUIS.' Rosario Banguis (Rosario) had signed the deed of sale as a witness. At the time of the acquisition and the issuance of the title, Rosario was legally married to Eduardo Nolasco, a marriage that was never annulled. Adriano died intestate in 1998. Procedural History: In 1999, Wenifreda filed a Petition for Cancellation of the TCT before the Regional Trial Court (RTC) of Malolos, Bulacan, alleging that the registration was erroneous due to 'insidious machination.' Rosario opposed, claiming she purchased the property with her personal funds and that she was Adriano's wife. The RTC ruled in favor of Wenifreda, ordering the cancellation of the TCT and the issuance of a new one in the name of Adriano married to Wenifreda. The Court of Appeals (CA) affirmed the RTC's decision but deleted the awards for damages and attorney's fees. The Petition: Rosario filed a Petition for Review on Certiorari under Rule 45, arguing that the RTC lacked jurisdiction because Section 108 of Presidential Decree No. 1529 (PD 1529) applies only to non-controversial clerical errors. She contended that her 'serious and weighty' objections regarding ownership and the rights of her son Adrian required a separate action in a court of general jurisdiction. She further argued that the property was owned in common by her and Adriano under Article 148 of the Family Code.
Issue(s)
Whether the Regional Trial Court (RTC) had jurisdiction under Section 108 of Presidential Decree No. 1529 (PD 1529) to resolve the petition for cancellation and correction of the Transfer Certificate of Title (TCT) despite the controversial nature of the opposition. Whether the subject property is part of the conjugal partnership of Adriano and Wenifreda or the exclusive property of Rosario. Whether the Court of Appeals (CA) erred in sustaining the execution pending appeal.
Ruling
The Supreme Court DENIED the petition and AFFIRMED the Decision of the Court of Appeals.
Ratio Decidendi
On Issue 1: The Supreme Court held that the Regional Trial Court (RTC) was not precluded from resolving the objections raised by Rosario. Under Section 2 of Presidential Decree No. 1529 (PD 1529), the distinction between the RTC sitting as a land registration court and as a court of general jurisdiction has been eliminated. The Court emphasized that Rosario's active participation in the trial, where she presented evidence and sought affirmative relief, constituted an invocation of the court's jurisdiction and a willingness to abide by its resolution. Therefore, she is barred from later impugning the court's jurisdiction. The proceeding under Section 108 was appropriate because the Registrar of Deeds committed a clear error in naming Rosario as Adriano's spouse when Wenifreda was the lawful wife. On Issue 2: The Court ruled that the preponderance of evidence established Wenifreda as the legitimate spouse of Adriano. Documentary evidence, including marriage contracts, proved that both Adriano and Rosario had subsisting marriages with other people at the time the property was acquired. The Court clarified that Philippine law does not recognize common-law marriages for the purpose of property registration when there is a legal impediment to marry. Furthermore, the Court noted that registration is not the equivalent of title; it is merely evidence thereof. Rosario failed to prove she contributed funds for the purchase, and the deed of sale explicitly named Adriano as the sole vendee, while Rosario signed only as a witness. On Issue 3: The Court found it unnecessary to resolve the issue regarding the execution pending appeal. Since the Court affirmed the final judgment on the merits, the questions regarding the propriety of the March 30, 2004 Order directing the issuance of a writ of execution have become moot and academic. The cancellation of the old title and the issuance of the new title in Wenifreda's name are now final and valid based on the resolution of the substantive issues of the case.
Main Doctrine
The Regional Trial Court (RTC), acting as a land registration court, now has the authority to hear and determine all questions arising from petitions filed after original registration, including those involving controversial issues. This is because Section 2 of Presidential Decree No. 1529 (PD 1529) eliminated the distinction between the general jurisdiction of the RTC and its limited jurisdiction as a land registration court under the old Act No. 496. Consequently, a summary proceeding for the correction of a certificate of title under Section 108 can proceed even if the opposition raises ownership claims, especially when the opposing party has freely submitted evidence and participated in the trial, thereby invoking the court's jurisdiction.