Land Titles Case Digest Week1

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Torrens System of Land Registration

Republic v. Hon. Umali


G.R. No. 80687, 10 April 1989
Facts:
The petitioner seeks reversion of a parcel of land on the ground that the original sale thereof from
the government was tainted with fraud because based on a forgery and therefore void ab initio. The
present holders of the property claiming to be innocent purchasers for value and not privy to the
alleged forgery, contend that the action cannot lie against them.

1) Land in question originally purchased on installment from the government by Florentina


Bobadilla, who transferred her right thereto in favor of Martina Cenizal, et al. Tomasa and Julio
assigned their shares to Martina, Maria and Gregorio, who, in 1971, signed a joint affidavit that
they were entitled to the issuance of a certificate of title over the said land, and that they had
already paid in full.
2) Sec. of Agriculture and Natural Resources executed a deed, and thereafter a TCT. Several
transfers thereafter followed.
3) Republic filed a complaint for reversion on the ground that the original sale of the land was
tainted with fraud based on forgery, and therefore, void ab initio; claimed that Gregorio died in
1943, Maria in 1959, and could not have signed the joint affidavit.
4) Respondent claimed that they all acquired the property in good faith and for value, invoked
estoppel, laches, prescription and res judicata, others invoked no cause of action as no rights
were violated, government not a real party-in-interest because the land is already covered by
Torrens system.
Issue:
May deception/fraud in the registration of title make the sale null and void, so as to make all
titles derived therefrom ineffectual ab initio?
Ruling:
No. The status of the defendants as innocent transferees for value was never questioned, and
such accorded them the protection of the Torrens system, thus rendering the titles obtained
indefeasible and conclusive.

In the present case, the private respondents acquired the land not by direct grant but in fact
after several transfers following the original sales thereof. They are presumed to be innocent
transferees for value.
The land now being registered under the Torrens system, the government has no more control
or jurisdiction over it; it is no longer part of the public domain.
NB:
A holder in bad faith is not entitled to the protection of the law.
If the patent and the OCT were procured by means of fraud, the land would not revert back to
the State precisely because it has become a private land. The original transfer was not null and
void ab initio but was only voidable. The land remained private as long as the title thereto had
not been voided. In such case, the nullity arises, not from fraud or deceit, but from the fact that
the land is not under the jurisdiction of the Bureau of Lands (now Land Management Bureau).

Sec. 39, Land Registration Act:


Every person receiving a certificate of title in pursuance of a decree of registration, and every
subsequent purchaser of registered land who takes/taking a certificate of title for value in good
faith shall hold the same free of all encumbrance except those noted on said certificate.
Sec. 44, P.D. 1529 – Property Registration Decree:
Every registered owner receiving a certificate of title in pursuance of a decree of registration,
and every subsequent purchaser of registered land taking a certificate of title for value and in
good faith, shall hold the same free from all encumbrances except those noted on said
certificate and any of following encumbrances which may be subsisting, and enumerated in
law.
RULING:
We find that the private respondents are transferees in good faith and for value of the subject
property and that the original acquisition thereof, although fraudulent, did not affect their own
titles. These are valid against the whole world, including the government.
ACCORDINGLY, the petition is DENIED, without any pronouncement as to costs. It is so ordered.
Traders Royal Bank vs. Court of Appeals, Patria Capay, et al
G.R. No. 118862, Sept. 24, 1999 (315 SCRA 190)
Facts:
A parcel of land owned by the spouses Capay was mortgage to and subsequently extra judicially
foreclosed by Traders Royal Bank (TRB). To prevent property sale in public auction, the Capays
filed a petition for preliminary injunction alleging the mortgage was void because they did not
receive the proceeds of the loan. A notice of lis pendens (suit pending) was filed before the
Register of Deeds with the notice recorded in the Day Book. Meanwhile, a foreclosure sale
proceeded with the TRB as the sole and winning bidder. The Capays title was cancelled and a new
one was entered in TRB’s name without the notice of lis pendens carried over the title. The
Capays filed recovery of the property and damages. Court rendered a decision declaring the
mortgage was void for want of consideration and thus cancelled TRB’s title and issued a new cert.
of title for the Capays.
Pending its appeal before the court, TRB sold the land to Santiago who subsequently subdivided
and sold to buyers who were issued title to the land. Court ruled that the subsequent buyers
cannot be considered purchasers for value and in good faith since they purchase the land after it
became a subject in a pending suit before the court. Although the lis pendens notice was not
carried over the titles, its recording in the Day Book constitutes registering of the land and notice
to all persons with adverse claim over the property. TRB was held to be in bad faith upon selling
the property while knowing it is pending for litigation. The Capays were issued the cert. of title
of the land in dispute while TRB is to pay damages to Capays.
Issue:
Who has the better right over the land in dispute?
Whether or not TRB is liable for damages
HELD:
The court ruled that a Torrens title is presumed to be valid which purpose is to avoid conflicts of
title to real properties. When the subsequent buyers bought the property there was no lis
pendens annotated on the title. Every person dealing with a registered land may safely rely on
the correctness of the title and is not obliged to interpret what is beyond the face of the
registered title. Hence the court ruled that the subsequent buyers obtained the property from a
clean title in good faith and for value. On one hand, the Capays are guilty of latches. After they
filed the notice for lis pendens, the same was not annotated in the TRB title. They did not take
any action for 15 years to find out the status of the title upon knowing the foreclosure of the
property. In consideration to the declaration of the mortgage as null and void for want of
consideration, the foreclosure proceeding has no legal effect. However, in as much as the Capays
remain to be the real owner of the property it has already been passed to purchasers in good
faith and for value. Therefore, the property cannot be taken away to their prejudice. Thus, TRB
is duty bound to pay the Capays the fair market value of the property at the time they sold it to
Santiago.
RULING:

WHEREFORE, the Decision of the Court of Appeals dated February 24, 1994 in CA-G.R. C.V. No.
33920, as modified by its Resolution dated August 10, 1994 is hereby AFFIRMED. In addition,
Traders Royal Bank is ordered to pay the Capays the amount of P47,730.00, with 12% interest from
the date of said sale until the same is paid.

This Decision is without prejudice to whatever criminal, civil or administrative action against the
Register of Deeds and/or his assistants that may be take by the party or parties prejudiced by the
failure of the former to carry over the notice of lis pendens to the certificate of title in the name of
TRB. 1âwphi1.nêt

SO ORDERED.

Legarda vs. Saleeby


G.R. No. 8936
October 2, 1915

FACTS: The plaintiffs (Legarda) and the defendant occupy, as owners, adjoining lots in
the district of Ermita in the city of Manila. There exists and has existed a number of years
a stone wall between the said lots. Said wall is located on the lot of the plaintiffs. The
plaintiffs, March 2, 1906, presented a petition in the Court of Land Registration for the
registration of their lot, which decreed that the title of the plaintiffs should be registered
and issued to them the original certificate provided for under the Torrens system. Said
registration and certificate included the wall.

Later the predecessor of the defendant presented a petition in the Court of Land
Registration for the registration of the lot now occupied by him. On March 25, 1912, the
court decreed the registration of said title and issued the original certificate provided for
under the Torrens system. The description of the lot given in the petition of the
defendant also included said wall.

On December 13, 1912 the plaintiffs discovered that the wall which had been included in
the certificate granted to them had also been included in the certificate granted to the
defendant .They immediately presented a petition in the Court of Land Registration for
an adjustment and correction of the error committed by including said wall in the
registered title of each of said parties.

The lower court however, without notice to the defendant, denied said petition upon the
theory that, during the pendency of the petition for the registration of the defendant’s
land, they failed to make any objection to the registration of said lot, including the wall,
in the name of the defendant.

ISSUE: Who is the owner of the wall and the land occupied by it?

HELD: The decision of the lower court is based upon the theory that the action for the
registration of the lot of the defendant was a judicial proceeding and that the judgment or
decree was binding upon all parties who did not appear and oppose it

Granting that theory to be correct one, then the same theory should be applied to the
defendant himself. Applying that theory to him, he had already lost whatever right he had
therein, by permitting the plaintiffs to have the same registered in their name, more than
six years before. Having thus lost his right, may he be permitted to regain it by simply
including it in a petition for registration?
For the difficulty involved in the present case the Act (No. 496) provides for the
registration of titles under the Torrens system affords us no remedy. There is no provision
in said Act giving the parties relief under conditions like the present. There is nothing in
the Act which indicates who should be the owner of land which has been registered in the
name of two different persons.

We have decided, in case of double registration under the Land Registration Act, that the
owner of the earliest certificate is the owner of the land. May this rule be applied to
successive vendees of the owners of such certificates? Suppose that one or the other of the
parties, before the error is discovered, transfers his original certificate to an “innocent
purchaser.” The general rule is that the vendee of land has no greater right, title, or
interest than his vendor; that he acquires the right which his vendor had, only. Under that
rule the vendee of the earlier certificate would be the owner as against the vendee of the
owner of the later certificate.

It would be seen to a just and equitable rule, when two persons have acquired equal rights
in the same thing, to hold that the one who acquired it first and who has complied with
all the requirements of the law should be protected.

In view of our conclusions, above stated, the judgment of the lower court should be and is
hereby revoked. The record is hereby returned to the court now having and exercising the
jurisdiction heretofore exercised by the land court, with direction to make such orders
and decrees in the premises as may correct the error heretofore made in including the
land in the second original certificate issued in favor of the predecessor of the appellee, as
well as in all other duplicate certificates issued.

(Land Titles and Deeds – Purpose of the Torrens System of Registration)


Facts: A stone wall stands between the adjoining lot of Legarda and Saleeby. The said
wall and the strip of land where it stands is registered in the Torrens system under the
name of Legarda in 1906. Six years after the decree of registration is released in favor
of Legarda, Saleeby applied for registration of his lot under the Torrens system in 1912,
and the decree issued in favor of the latter included the stone wall and the strip of land
where it stands.
Issue: Who should be the owner of a land and its improvement which has been
registered under the name of two persons?
Held: For the issue involved, The Land Registration Act (Act 496) affords no remedy.
However, it can be construed that where two certificates purports to include the same
registered land, the holder of the earlier one continues to hold title and will prevail.
The real purpose of the Torrens system of registration, is to quiet title to land; to put a
stop forever to any question of the legality of the title, except claims which were noted at
the time of registration, in the certificate, or which may arise subsequent thereto. That
being the purpose of the law, once a title is registered the owner may rest secure,
without the necessity of waiting in the portals of the court, or sitting in the “mirador de su
casa,” to avoid the possibility of losing his land.
The law guarantees the title of the registered owner once it has entered into the Torrens
system.

Casimiro Development Corp. v. Mateo


G.R. No. 175485, 24 July 2011

Facts:
1) Registered parcel of land originally owned by Isaias Lara, respondents’ maternal grandfather,
which was passed on to his children.

2) The co-heirs effected the transfer of the full and exclusive ownership to Felicidad Lara-Mateo.

3) Deed of sale was executed in favor of Laura, one of Felicidad’s children, who applied for land
registration; OCT was thereafter issued.

4) Property used as collateral to secure a succession of loans, a TCT of which was eventually
issued in the name of China Bank.

5) Casimiro Development Corp. thereafter purchased the property from CB; Felicidad died
intestate.

6) CDC brought action for unlawful detainer in the MeTC against the sons of Felicidad; the latter
claimed MeTC did not have jurisdiction; the land was classified as agricultural; has been in
continuous possession of the land.

7) MeTC ruled in favor of CDC, RTC against, CA and SC in favor CDC.

8) Respondent brought action for quieting of title, RTC favored CDC, CA against (not a buyer in
good faith).

Issue:
Is the concerned Certificate of Title in the name of Laura indefeasible and imprescriptible?

Ruling:
Yes. The property has already been placed under the Torrens system of land registration before
CDC became the registered owner by purchase from China Bank; OCT has already been issued to
attest to the fact that the person named in the certificate is the owner of the property therein
described, subject to liens and encumbrances as thereon noted or what the law warrants or reserves.
Neither the respondent nor his siblings opposed the transactions causing various transfers, and
even acknowledged the registration of the land under the name of Laura.

CDC was an innocent purchaser for value. Considering that China Bank’s TCT was 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.
NB:
If a person purchases a piece of land on the assurance that the seller’s title thereto is valid, he
should not run the risk of being told later that his acquisition was ineffectual after all, which will
not only be unfair to him as the purchaser, but will also erode public confidence in the system and
will force land transactions to be attended by complicated and not necessarily conclusive
investigations and proof of ownership.

The Torrens certificate of title is merely an evidence of ownership or title in the particular
property described therein. The issuance of the certificate of title to a particular person does not
preclude the possibility that persons not named in the certificate may be co-owners of the real
property therein described with the person named therein, or that the registered owner may be
holding the property in trust for another person.

Registration of land under the Torrens System, aside from perfecting the title and rendering it
indefeasible after the lapse of the period allowed by law, also renders the title immune from
collateral attack.

Casimiro Development Corporation vs. Renato L. Mateo


G.R. No. 175485, July 17, 2011

FACTS:

In 1988, petitioner purchased from China Bank the land in question which was previously sold by
the mother of Mateo to Rodolfo Pe who in turn constituted a mortgage on the property in favor
of China Bank as security for a loan. China Bank foreclosed the mortgage and consolidated its
ownership of the property after Rodolfo failed to redeem. A TCT was issued in the name of China
Bank. In 1991, CDC brought an action for unlawful detainer against the respondent’s
siblings. Respondent counters that CDC acquired the property from China Bank in bad faith
because it had actual knowledge of the possession of the property by the respondent and his
siblings.

ISSUE:

WON CDC was an innocent purchaser for value.

HELD:

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 is charged with notice only of
such burdens and claims as are annotated on the title. China Bank’s TCT’s 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. The
respondent’s siblings’ possession did not translate to an adverse claim of ownership. They even
characterized their possession only as that of mere agricultural tenants. Under no law was
possession grounded on tenancy a status that might create a defect or inflict a law in the title of
the owner. CDC having paid the full and fair price of the land, was an innocent purchaser for
value. The TCT in the name of CDC was declared valid and subsisting.

FRANCISCO MADRID V. SPOUSES MAPOY (G.R. NO. 150887, AUGUST 14, 2009, 596 SCRA 14, 26-27).

IN THIS CASE THE SUPREME COURT RULED THAT REGISTRATION OF LAND UNDER THE TORRENS SYSTEM,
ASIDE FROM PERFECTING THE TITLE AND RENDERING IT INDEFEASIBLE AFTER THE LAPSE OF THE PERIOD
ALLOWED BY LAW, ALSO RENDERS THE TITLE IMMUNE FROM COLLATERAL ATTACK.

WHAT IS COLLATERAL ATTACK?

IT IS AN ATTACK ON A JUDGMENT GRANTING TITLE BUT MADE IN ANOTHER ACTION TO OBTAIN A


DIFFERENT RELIEF, SUCH AS POSSESSION.

WHAT IS A DIRECT ATTACK?

IT IS AN ATTACK AGAINST A JUDGMENT GRANTING THE TITLE, THROUGH AN ACTION WHOSE MAIN
OBJECTIVE IS TO ANNUL, SET ASIDE, OR ENJOIN THE ENFORCEMENT OF SUCH JUDGMENT IF NOT YET
IMPLEMENTED, OR TO SEEK RECOVERY IF THE PROPERTY TITLED UNDER THE JUDGMENT HAD BEEN
DISPOSED OF.

WHY IS COLLATERAL ATTACK NOT PERMITTED?

BECAUSE TO PERMIT A COLLATERAL ATTACK ON A TORRENS TITLE IS TO WATER DOWN THE INTEGRITY
AND GUARANTEED LEGAL INDEFEASIBILITY OF A TORRENS TITLE.

WHY DOES CRISOLOGO HAVE A BETTER RIGHT OF POSSESSION?

THE TESTIMONIAL AND DOCUMENTARY EVIDENCE ON RECORD PROVE THAT CRISOLOGO HAS A
PREFERRED CLAIM OF POSSESSION OVER THAT OF PETITIONERS.

SHE BOUGHT THE SUBJECT PROPERTIES FROM THE PREVIOUS OWNER IN 1967, WHICH WAS WHY THE
TRANSFER CERTIFICATES OF TITLE WERE SUBSEQUENTLY ISSUED IN HER NAME.

RECORDS FURTHER SHOW THAT SHE HAS BEEN PAYING THE REALTY TAXES ON THE SAID PROPERTIES
SINCE 1969.

SHE LIKEWISE APPOINTED ISICAN AS ADMINISTRATOR OF THE DISPUTED LANDS.

MORE IMPORTANTLY, THERE IS NO QUESTION THAT SHE OFFERED TO SELL TO PETITIONERS THE
PORTIONS OF THE SUBJECT PROPE1IIES OCCUPIED BY THEM.

HENCE, SHE DESERVES TO BE RESPECTED AND RESTORED TO HER LAWFUL POSSESSION AS PROVIDED IN
ARTICLE 539 OF THE NEW CIVIL CODE.

FRANCISCO MADRID, Petitioners vs. SPOUSES BONIFACIO MAPOY, Respondents


G.R. No. 150887 August 14, 2009

FACTS:

1. The spouses Bonifacio and Felicidad Mapoy (respondents-plaintiffs) are the absolute owners of
two parcels of land (the properties).
2. On April 4, 1988, the respondents-plaintiffs sought to recover possession of the properties
through an accion publiciana filed with the Regional Trial Court (RTC) of Manila against Gregorio
Miranda and his family (Mirandas) and two other unnamed defendants.
3. The respondents-plaintiffs alleged that they acquired the properties from the spouses Procopio
and Encarnacion Castelo under a Deed of Absolute Sale dated June 20, 1978. They merely
tolerated the petitioners-defendants’ continued occupancy and possession until their possession
became illegal when demands to vacate the properties were made. Despite the demands, the
petitioners-defendants continued to occupy and unlawfully withhold possession of the properties
from the respondents-plaintiffs, to their damage and prejudice.
4. Efforts to amicably settle the case proved futile, leaving the respondents-plaintiffs no recourse
but to file a complaint for ejectment which the lower court dismissed because the respondents-
plaintiffs should have filed an accion publiciana. Thus, they filed their complaint for accion
publiciana, praying for recovery of possession of the properties.
5. The Mirandas countered that Gregorio Miranda owned the properties by virtue of an oral sale
made in his favor by the original owner, Vivencio Antonio (Antonio). They claimed that in 1948,
Gregorio Miranda was Antonio’s carpenter, and they had a verbal contract for Miranda to stay in,
develop, fix and guard the properties; in 1972, Antonio gave the properties to Gregorio Miranda
in consideration of his more than twenty (20) years of loyal service.
6. The RTC ruled in favor of respondents-plaintiffs. Upon appeal, the CA the affirmed the decision of
RTC. Hence this petition to the SC.

ISSUE:

Who must have the possession of the property? Petitioners.

HELD:
accion publiciana, also known as accion plenaria de posesion, is a plenary action for the recovery of
possession in an ordinary civil proceeding to determine the better and legal right to possess,
independently of title.

The objective of the plaintiffs in accion publiciana is to recover possession only, not ownership.
However, where the parties raise the issue of ownership, the courts may pass upon the issue to determine
who between or among the parties has the right to possess the property. This adjudication, however, is
not a final and binding determination of the issue of ownership; it is only for the purpose of resolving the
issue of possession, where the issue of ownership is inseparably linked to the issue of possession. The
adjudication of the issue of ownership, being provisional, is not a bar to an action between the same
parties involving title to the property. The adjudication, in short, is not conclusive on the issue of
ownership.
In the present case, both the petitioners-defendants and the respondents-plaintiffs raised the
issue of ownership. The petitioners-defendants claim ownership based on the oral sale to and occupation
by Gregorio Miranda, their predecessor-in-interest, since 1948. On the other hand, the respondents-
plaintiffs claim that they are the owners, and their ownership is evidenced by the TCTs in their names.
Under this legal situation, resolution of these conflicting claims will depend on the weight of the parties'
respective evidence, i.e., whose evidence deserves more weight.

In the present case, both the RTC and the CA gave more weight to the certificate of title the
respondents-plaintiffs presented, and likewise found that the petitioners-defendants' possession of the
properties was merely upon the respondents-plaintiffs’ tolerance. We see no reason to doubt or question
the validity of these findings and thus recognize their finality.

As a matter of law, a Torrens Certificate of Title is evidence of indefeasible title of property in


favor of the person in whose name the title appears. The title holder is entitled to all the attributes of
ownership of the property, including possession, subject only to limits imposed by law. In the present
case, the respondents-plaintiffs are indisputably the holders of a certificate of title against which the
petitioners-defendants’ claim of oral sale cannot prevail. As registered titleholders, they are entitled to
possession of the properties.

Teoville Homeowners Asso., Inc. v. Ferreira, et al.,


G.R. No. 140086. June 8. 2005

Facts: This case stemmed from a dispute over a 71l-square meter lot designated as Lot 98
of the Teoville Subdivision in Parafiaque City previously owned by the Villongco Realty
Corporation. Based on the original plans of the subdivision project approved by the
Municipal Council of Parafiaque City in 1968, the lot was designated as a saleable lot.
Before its completion, however, Villongco Realty Corporation transferred the subdivision
project, including all the unsold lots therein, through a Deed of Sale and Assignment to
REAM Development Corporation (REAM). The sale included all the improvements
erected upon Lot 98 such as the water system, equipment and appurtenances thereto.

Sometime in 1985, the residents experienced a severe water crisis occasioned by the
complete breakdown of the centralized water system and a dispute between REAM and
Teoville (Paraflaque) Homeowners Association, Inc. (Teoville) as to who was responsible
for the unpaid electricity bills of the centralized water system.

Through a Deed of Transfer and Donation REAM donated to Teoville the water
distribution system of 30,000.00 gallons capacity water tank, including the 3O-
horsepower deepwell submersible motor pump, respectively, all their facilities and
appurtenances thereof. The water pump and the water tank soon became unoperational
and were subsequently dismantled.

On 16 April 1985, with the approval of the Land Registration Authority, REAM caused the
subdivision of Lot 98 into Lot 98-A with an area of 300 square meters and Lot 98- B with
an area of 4ll square meters. REAM then sold Lot 98-A to Edward L. Ferreira on 20
September 1985. By virtue of the sale of the lot to Ferreira, Transfer Certificate of Title
(TCT) No. 95354 of the Registry of Deeds of Pasay City in the name of REAM was
cancelled and TCT No. 102423 was issued in the name of Ferreira.

Teoville filed a Verified Complaint before the Adjudication Board of the Housing and
Land Use Regulatory Board (HLURB) against REAM Development Corporation and
Edward Ferreira arguing that the sale between REAM and Ferreira was illegal and should
be annulled because REAM cannot dispose of Lot 98 since it is an open space where the
water tank which allegedly belongs to the homeowners association was built.

In lieu of an Answer, Ferreira filed a Motion to Dismiss on the ground of lack of


jurisdiction.

HLURB's Ruling: HLURB Arbiter dismissed the Complaint for lack of jurisdiction
rationalizing that since the Registry of Deeds of Pasay City had already issued a title to
Lot 98-A, the appropriate Regional Trial Court and not the HLURB had jurisdiction to
declare the nullity of the Torrens Title issued to Ferreira and ordering REAM to comply
with its undertaking to donate Lot 98-B to Teoville.

On appeal, the HLURB Board of Commissioners rendered a decision setting aside the
decision of HLURB Arbiter stating that while Lot 98 previously appeared to be a saleable
lot, however, since the water system, a form of subdivision development, was situated in
Lot 98, REAM, in effect, made a representation that the lot was part of the open space, a
facility for public use.

The re-subdivision thereof resulted in the alteration of an open space which to be valid
required the prior approval of the HLURB upon written conformity or consent of the
homeowners, under PD 957. On motion for reconsideration, the HLURB Board of
Commissioners, Special Division, set aside the earlier decision of the HLURB Board of
Commissioners and held that REAM had the right to re-subdivide Lot 98 without prior
clearance from the HLURB because there was no more facility for public use set up therein
and further held that since REAM M DG-F 1919: Enhancing Access to and Provision of
Water Services with the Active Participation of the Poor for the Compilation and Analysis
of Jurisprudence on Water Supply case Digests with Analysis of expressed willingness to
donate Lot 98-B to Teoville, the HLURB Board of Commissioners "can only go so far as
directing REAM to comply with its voluntary undertaking."

Teoville's MR was denied on the ground that the water system in Lot 98 was no longer
functioning.

Office of the President's Ruling: The OP dismissed Teoville's appeal and the resolutions
of the HLURB Board of Commissioners, Special Division, were affirmed in toto.

Appellate Court's Ruling: The CA dismissed the petition due to technicality.

Issue: Whether HLURB's findings of fact are accorded with great respect Supreme Court's
Ruling: On the issue of substance, a less stringent interpretation of the rules is not
justified in this case which raises factual issues already passed upon by both the HLURB
and the Office of the President. Findings of fact by administrative agencies are generally
accorded great respect, if not finality, by the Court because of the special knowledge and
expertise over matters falling under their jurisdiction. More, the title to the land of
Ferreira has acquired the character of indefeasibility having been registered under the
Torrens system of registration. Once a decree of registration is made under the Torrens
system, and the reglementary period has passed within which the decree may be
questioned, the title is perfected and cannot be collaterally questioned later on.

To permit a collateral attack on his title, such as what petitioner now attempts, would
reduce the vaunted legal indefeasibility of Torrens Title to meaningless verbiage. A
Torrens Title cannot be collaterally attacked. A direct attack against a judgment is made
through an action or proceeding the main object of which is to annul, set aside, or enjoin
the enforcement of such judgment, if not yet carried into effect; or, if the property has
been disposed of, the aggrieved party may sue for recovery. A collateral attack is made
when, in another action to obtain a different relief, an attack on the judgment is made as
an incident in said action. It has, therefore, become an ancient rule that the issue on the
validity of title, i.e., whether or not it was fraudulently issued, can only be raised in an
action expressly instituted for that purpose.

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