Saturday, November 14, 2015

SPOUSES CARPO v. AYALA LAND, INCORPORATED [G.R. No. 166577 February 3, 2010]


[G.R. No. 166577 February 3, 2010]


Land Titles and Deeds Case Digest by John Paul C. Ladiao (11 Sept 2015)

Topic: Survey of the Land – Forms and Contents (Section 15-19)

On February 16, 1995, petitioner spouses Morris and Socorro Carpo (Carpos) filed a Complaint for Quieting of Title  with the RTC of Makati City against Ayala Corporation, Ayala Property Ventures Corporation (APVC), and the Register of Deeds of Las Pias. 

In their Complaint, the Carpos claimed to be the owners of a 171,209-square meter parcel of land covered by Transfer Certificate of Title (TCT) No. 296463 issued in their names.  They further alleged that Ayala Corporation was claiming to have titles (specifically, TCT Nos. 125945, T-4366, T-4367 and T-4368) over the property covered by the Carpos TCT No. 296463 and that Ayala Corporation had made such property its equity contribution in APVC to be developed into a residential subdivision.

According to the complaint, TCT Nos. 125945, T-4366, T-4367 and T-4368 and their derivatives appear to have been issued in the name of Ayala and purport to cover and embrace the Carpos property or portion thereof duly covered registered under the already indefeasible and incontrovertible TCT [No.] 296463 are inherently invalid and enforceable (sic) for not being the duly issued derivatives of the Carpos title.  The Carpos additionally applied for a restraining order and writ of preliminary injunction to enjoin Ayala Corporation and APVC from doing construction and development works on the properties in purported violation of the Carpos rights. 


NO. Petitioners clearly misunderstood or deliberately misread the CAs ruling on this point. It is the CAs view that the trial courts pronouncement that OCT No. 242 was issued without an approved survey plan was unwarranted in view of the presumption of regularity that said title enjoys.

It is admitted that a survey plan is one of the requirements for the issuance of decrees of registration, but upon the issuance of such decree, it can most certainly be assumed that said requirement was complied with by ALIs original predecessor-in-interest at the time the latter sought original registration of the subject property. Moreover, the land registration court must be assumed to have carefully ascertained the propriety of issuing a decree in favor of ALIs predecessor-in-interest, under the presumption of regularity in the performance of official functions by public officers. The court upon which the law has conferred jurisdiction, is deemed to have all the necessary powers to exercise such jurisdiction, and to have exercised it effectively. This is as it should be, because once a decree of registration is made under the Torrens system, and the time has passed within which that decree may be questioned the title is perfect and cannot later on be questioned. There would be no end to litigation if every litigant could, by repeated actions, compel a court to review a decree previously issued by another court forty-five (45) years ago. The very purpose of the Torrens system would be destroyed if the same land may be subsequently brought under a second action for registration, as what the court a quo did when it faulted ALIs failure to allege that its predecessor-in-interest submitted a survey plan approved by the Director of the Bureau of Lands in the original land registration case.

The Court need not emphasize that it is not for ALI to allege in its pleadings, much less prove, that its predecessor-in-interest complied with the requirements for the original registration of the subject property. A party dealing with a registered land need not go beyond the Certificate of Title to determine the true owner thereof so as to guard or protect his or her interest. Hence, ALI was not required to go beyond what appeared in the transfer certificate of title in the name of its immediate transferor. It may rely solely, as it did, on the correctness of the certificate of title issued for the subject property and the law will in no way oblige it to go behind the certificate of title to determine the condition of the property. This is the fundamental nature of the Torrens System of land registration, to give the public the right to rely upon the face of a Torrens certificate of title and to dispense with the need of inquiring further.

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