Case on indefeasibility of torrens titles

Spouses Alfonso and Maria Angeles Cusi, Petitioners, vs. Lilia V. Domingo, Respondent.

G.R. No. 195825; February 27, 2013

Ramona Liza L. De Vera, Petitioner, vs. Lilia V. Domingo and Spouses Radella and Alfred Sy, Respondents

G.R. No. 195871

Facts: Lilia Domingo owned a certain real property which was vacant and unfenced. After some time, a construction activities were being undertaken on her property without her knowledge and more so, without her consent. She soon was able to discover a series of anomalous transactions involving her property. It turned out that Radella Sy was able to execute a falsified deed of sale and thereafter, acquired a valid title to the property. Sy then divided the property into two and sold each half to spouses De Vera and Spouses Cusi, and both buyers were able to have valid titles to the property on their names. All of the said transactions took place without the knowledge of the real owner Lilia Domingo. Upon learning of the circumstances, Domingo filed a case at the RTC seeking annulment or cancellation of the titles issued. The RTC rendered a decision, affirmed by the CA in favor of Lilia Domingo.

Issue:  What is the effect of acquiring a real property under the Torrens System of Land Registration?

Ruling:  Under the Torrens system of land registration, the State is required to maintain a register of landholdings that guarantees indefeasible title to those included in the register. The State issues an official certificate of title to attest to the fact that the person named is the owner of the property described therein, subject to such liens and encumbrances as thereon noted or what the law warrants or reserves. One of the guiding tenets underlying the Torrens system is the curtain principle, in that one does not need to go behind the certificate of title because it contains all the information about the title of its holder. This principle dispenses with the need of proving ownership by long complicated documents kept by the registered owner, which may be necessary under a private conveyancing system, and assures that all the necessary information regarding ownership is on the certificate of title. Consequently, the avowed objective of the Torrens system is to obviate possible conflicts of title by giving the public the right to rely upon the face of the Torrens certificate and, as a rule, to dispense with the necessity of inquiring further; on the part of the registered owner, the system gives him complete peace of mind that he would be secured in his ownership as long as he has not voluntarily disposed of any right over the covered land.

           

The petitioners were shown to have been deficient in their vigilance as buyers of the property. It was not enough for them to show that the property was unfenced and vacant; otherwise, it would be too easy for any registered owner to lose her property, including its possession, through illegal occupation. In view of the foregoing, the court affirmed the decision of the lower courts and restores to Domingo her rights of dominion over the property.