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Liao VS Ca
Liao VS Ca
CA
G.R. Nos. 102961-62. January 27, 2000
Petitioner Jesus P. Liao seeks to annul the decisions of the Court of Appeals which annulled an order of the Regional Trial Court, Quezon City, Branch 99 directing the Register of Deeds to issue transfer titles to Estrella Mapa over certain lots in Piedad Estate, Quezon City.
facts
On March 5, 1986, Estrella Mapa filed with the Regional Trial Court a petition for reconstitution of documents and issuance of certificates of title over certain parcels of land. Estrella Mapa claimed that on June 16, 1913, the Director of Lands issued certificates of sales to her predecessor-in-interest, Vicente Salgado, over the same parcels of land in accordance with Act. No. 1120, otherwise known as the Friar Lands Act. After hearing, RTC ordered the issuance of certificate of titles in favor of Estrella Mapa.
facts
Estrella Mapa assigned the parcels of land covered by T.C.T. No. 348291 and T.C.T. No. 348292 in favor of Palmera Agricultural Realty Development Corporation, which is a family corporation headed by Lourdes Angeles, Estrella Mapas daughter. Re: G. R. Nos. 102961-62 On March 28, 1990, I.C. Cruz Construction, Inc. (ICC) filed with the Court of Appeals a petition for the annulment of the Order of the Regional Trial Court. I.C. Cruz alleged that the title issued by the Register of Deeds of Quezon City pursuant to said order encompassed property which had been registered and titled in its name.
facts
On July 3, 1990, Arle Realty Development Corporation (hereafter Arle) filed a similar petition with the Court of Appeals praying for the annulment of the same order of the Regional Trial Court. Arle claimed ownership of six (6) lots which had overlapped the property claimed by Estrella. After consolidation of the two cases, the Court of Appeals set the cases for preliminary conference on March 21, 1991. At this conference, Jesus P. Liao appeared with his counsel and claimed that he purchased the parcels of land from Palmera by virtue of a Deed of Omnibus Assignment dated August 23, 1990. CA declared the RTC order as null and void. Motion for reconsideration was likewise denied.
facts
Re: G. R. No. 107625 Respondents alleged that Lot 777 ceased to be part of Friar Land as early as May 1922 when the Director of Lands executed Deed of Sale No. 10570 conveying ownership of Lot 777 to one Carlos Sarmiento, not to Vicente Salgado. The lot could not have been validly assigned to defendant Estrella Mapa on April 12, 1930 by Vicente Salgado, who was not the rightful owner of the property. TCT 348292 was procured only in 1986 while the titles of plaintiffs were issued in 1967 and one was issued in 1958.
facts
It was found out that the land was fraudulently and irregularly issued, being a duplication of previously issued titles and recommending the filing of an action for the annulment of TCT Nos. 348156, 348291 and 348292 all in the name of Estrella Mapa. On July 24, 1990, the trial court rendered decision ruling, citing de Villa vs. Trinidad, 22 SCRA 1167, 1174 [1968], that "where two certificates of title are issued to different persons covering the same land in whole or in part, the earlier in date must prevail as between the original parties and in case of successive registrations where more than one certificate is issued over the land, the person holding under prior certificate is entitled to the land as against the persons who rely on the second certificate."
facts
CA affirmed. Hence, this petition.
facts
Re: G. R. No. 108759 On February 9, 1988, Edmund Ruiz, Romeo Gomez, and Rosalinda Villapa filed with the Regional Trial Court, Quezon City, Branch 105 a complaint for annulment of title, reconveyance of real property, damages, and injunction against Estrella Mapa. RTC declared the title of Estrella Mapa null and void. CA affirmed. Hence, this petition.
issue
whether or not the Court of Appeals erred in upholding the annulment of the order of the trial court in issuing certificates of title to Estrella Mapa.
sc ruling
Petitioner not owner of land The subject lots are part of the Piedad Estate, Quezon City, a Friar Land acquired by the Philippine Government as indicated in Public Act No. 1120 (Friar Lands Act). By virtue of Act No. 1120, the Piedad Estate was placed under the administration of the Director of Lands. Petitioner Liao claims that his predecessor in interest acquired the property through sale certificates Nos. 780, 781, 783, issued by the Director of Lands in 1913. It is shown, however, that the sale certificates were signed by the Director of Lands and approved by the Secretary of the Interior. These sales were void. This is because the sales were not approved by the Secretary of Agriculture and Natural Resources.
sc ruling
In view of the invalidity of the sales, there can be no valid titles issued on the basis of such sales. Double Sale the law provides that as between two purchasers, the one who registered the sale in his favor has a preferred right over the other who has not registered his title, even if the latter is in actual possession of the immovable property. "when two certificates of title are issued to different persons covering the same land in whole or in part, the earlier in date must prevail, and, in case of successive registrations where more than one certificate is issued over the same land, the person holding a prior certificate is entitled to the land as against a person who relies on a subsequent certificate.
sc ruling
Title not tantamount to ownership private respondents title must be respected. They have in their favor the law that protects holders of title under the torrens system of land registration. Although title does not vest ownership, time and again we have ruled that a torrens certificate is evidence of an indefeasible title to property in favor of the person whose name appears thereon. PETITION DISMISSED.