CDC v. Mateo

CDC v.
Mateo
Facts.
The land
subject of
dispute is a
parcel of land
located in Las
Piñas which
was originally
registered to
Isaias Lara
which was
passed to
Felicidad Lara
Mateo. The
said land was
used as a
collateral to
secure a
succession of
loans. That
when the TCT
of the said
land was in the
name of Pe
who
constituted a
mortgage to
China Bank
and when
payment of the
obligation, the
said property
was foreclosed
thus the TCT
was issued on
the former.
Subsequently,
CDC
purchased the
property from
China Bank.
CDC brought
an action for
unlawful
detainer
against the
respondent
siblings, the
occupant in
the land with
the MeTC. But
the defendants
claimed that
MeTC have no
jurisdiction
over the
action, because
the land in
dispute is an
agricultural
land thus
jurisdiction
belonged to the
DARAB.
Nevetheless,
MeTC ruled in
favor of CDC.
The said
decision was
assailed in the
RTC which
reversed the
ruling against
CDC finding
that MeTC
have no
jurisdiction.
Upon appeal-
affirmed the
MeTC’s
decision.
However,
Renato Mateo,
brother of
Laura,
brought an
action for
quieting of
title,
reconveyance
of four-fifths
of the land,
and damages
against CDC
and Laura in
the RTC in
Las Piñas City.
Issue: W/n the
concerned
Certificate of
Title in the
name of Laura
indefeasible
and
imprescriptibl
e?
Held: There is
no doubt that
the land in
question,
although once
a part of the
public domain,
has already
been placed
under the
Torrens
system of land
registration.
The
Government is
required
under the
Torrens
system of
registration to
issue an
official
certificate of
title to attest to
the fact that
the person
named in the
certificate is
the owner of
the property
therein
described,
subject to such
liens and
encumbrances
as thereon
noted or what
the law
warrants or
reserves. The
11
objective is to
obviate
possible
conflicts of
title by giving
the public the
right to rely
upon the face
of the Torrens
certificate and
to dispense, as
a rule, with the
necessity of
inquiring
further. The
Torrens
system gives
the registered
owner
complete peace
of mind, in
order that he
will be secured
in his
ownership as
long as he has
not voluntarily
disposed of
any right over
the covered
land.
The land in
question has
been covered
by a Torrens
certificate of
title (OCT No.
6386 in the
name of
Laura, and its
derivative
certificates)
before CDC
became the
registered
owner by
purchase from
China Bank.
In all that
time, neither
the respondent
nor his siblings
opposed the
transactions
causing the
various
transfers. In
fact, the
respondent
admitted in his
complaint that
the
registration of
the land in the
name of Laura
alone had been
with the
knowledge and
upon the
agreement of
the entire
Lara-Mateo
family. It is
unthinkable,
therefore, that
the
respondent,
fully aware of
the exclusive
registration in
her sister
Laura's name,
allowed more
than 20 years
to pass before
asserting his
claim of
ownership for
the first time
through this
case in mid-
1994. Making
it worse for
him is that he
did so only
after CDC had
commenced
the ejectment
case against
his own
siblings.
2. W/N CDC is
an innocent
purchaser for
value
The CA
plainly erred
in so finding
against CDC.
To start
with, one who
deals with
property
registered
under the
Torrens
system need
not go beyond
the certificate
of title, but
only has to
rely on the
certificate of
title. He
21
is
charged with
notice only of
such burdens
and claims as
are annotated
on the title.
considering
that China
Bank's TCT
No. 99527 was
a clean title,
that is, it was
free from any
lien or
encumbrance,
CDC had the
right to rely,
when it
purchased the
property,
solely upon the
face of the
certificate of
title in the
name of China
Bank. 24
The CA's
ascribing of
bad faith to
CDC based on
its knowledge
of the adverse
possession of
the
respondent's
siblings at the
time it
acquired the
property from
China Bank
was absolutely
unfounded and
unwarranted.
That
possession did
not translate to
an adverse
claim of
ownership that
should have
put CDC on
actual notice of
a defect or
flaw in the
China Bank's
title, for the
respondent's
siblings
themselves, far
from asserting
ownership in
their own
right, even
characterized
their
possession only
as that of mere
agricultural
tenants.

CDC v. Mateo

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