In Arjonillo v. Pagulayan, the Supreme Court reiterated that claiming ownership requires solid proof, not just attacking the current titleholder’s financial status. The Court emphasized the importance of presenting credible evidence, especially when challenging a registered land title. The decision underscores that mere allegations and hearsay are insufficient to overturn a Torrens title, reinforcing the stability and reliability of the Philippine land registration system. Those seeking to challenge an existing title must present convincing evidence to substantiate their claims of ownership.

Challenging Land Title: Can Allegations Override a Registered Deed?

The case revolves around a dispute over a property in Tuguegarao, Cagayan. After Avelardo Cue died intestate, his heirs, including Florencia Arjonillo, filed a case to recover a property registered under the name of Demetria Pagulayan. The heirs argued that although the land was under Pagulayan’s name, Cue had actually purchased it, and Pagulayan, being his paramour, unduly influenced him to register it in her name. The Regional Trial Court (RTC) initially sided with the heirs, but the Court of Appeals (CA) reversed this decision. Now, the Supreme Court has been asked to settle whether the heirs presented sufficient evidence to overcome Pagulayan’s registered title.

At the heart of this case lies the legal principle that the burden of proof rests on the party asserting a claim. In an accion reivindicatoria, like the one filed by Arjonillo and her co-heirs, the claimants must prove two critical elements as highlighted in Ibot v. Heirs of Francisco Tayco:

In order to successfully maintain actions for recovery of ownership of a real property, the complainants must prove the identity of the land and their title thereto as provided under Article 434 of the Civil Code.

The Supreme Court found that Arjonillo and her co-heirs failed to present convincing evidence that the property in question belonged to Cue’s estate. Instead, they focused on discrediting Pagulayan’s financial capacity to purchase the property, which the Court deemed insufficient to overturn her registered title. The heirs highlighted that Pagulayan was supposedly just a salesgirl, implying she could not have afforded the land. This argument, however, did not meet the required legal standard for proving ownership.

A significant part of the heirs’ case relied on the testimony of Dr. Benito Valdepanas, who claimed that Cue had told him he purchased the property from Spouses Chua. However, the Court deemed this testimony as hearsay, which is inadmissible as evidence. The Rules of Court are clear on this matter:

Rules of Court, Rule 130, Section 36: A witness can testify only to those facts which he knows of his own knowledge, that is, which are derived from his own perception.

Dr. Valdepanas was not a party to the sale transaction and merely repeated statements he heard from Cue and Chua Bun Gui. Since he lacked personal knowledge of the actual sale, his testimony could not be used as proof of Cue’s ownership. It is an established principle that hearsay evidence, even if not objected to, has no probative value and cannot be given credence.

In contrast, Pagulayan presented a notarized deed of absolute sale, Transfer Certificate of Title (TCT) No. T-35506, and real property tax receipts, all of which supported her claim of ownership. The Court of Appeals correctly observed that documentary and testimonial evidence clearly supported Pagulayan’s ownership of the disputed property, as reflected in the TCT issued in her name. This aligns with the fundamental principle that a certificate of title serves as evidence of an incontrovertible title to the property in favor of the person whose name appears therein, giving the titleholder all attributes of ownership, including possession of the property.

The Supreme Court underscored that merely questioning the title holder’s financial capacity is not sufficient to overcome the evidence of a registered title. Petitioners failed to provide convincing evidence to prove that the subject properties form part of Cue’s estate. The court noted that:

Rather than dispensing with their burden of proof as required under the law, Arjonillo and her co-heirs concentrated on attacking Pagulayan’s claim of ownership over the subject properties on the ground of the latter’s alleged lack of financial capability to purchase the land and erect a building thereon.

This case reinforces the principle that challenging a registered title requires concrete evidence and adherence to the rules of evidence. The stability of the Torrens system relies on the idea that titles are secure unless compelling proof is presented to the contrary.

In the context of property disputes, the principle of preponderance of evidence is crucial. As cited in Heirs of Alejandra Arado v. Heirs Alcoran, the party with the greater weight of evidence prevails:

Heirs of Alejandra Arado v. Heirs Alcoran, 763 Phil. 205, 216 (2015): [They] have the burden of proof to establish the averments in the complaint by preponderance of evidence, relying on the strength of their own evidence and not upon the weakness of their opponent’s evidence.

This means that Arjonillo and her co-heirs had to demonstrate that their claim of ownership was more convincing than Pagulayan’s. The Court determined that they failed to meet this standard, relying on conjecture and inadmissible hearsay evidence rather than presenting solid proof of Cue’s ownership.

FAQs

What was the key issue in this case?	The central issue was whether the heirs of Avelardo Cue presented sufficient evidence to overcome Demetria Pagulayan’s registered title to a disputed property, which they claimed Cue had actually purchased.
What is an accion reivindicatoria?	An accion reivindicatoria is an action to recover ownership of real property. The plaintiff must prove both the identity of the land and their title to it.
Why was Dr. Valdepanas’ testimony considered inadmissible?	Dr. Valdepanas’ testimony was deemed hearsay because he was not a party to the sale transaction and merely repeated statements he heard from others, lacking personal knowledge of the actual sale.
What evidence did Demetria Pagulayan present to support her claim of ownership?	Pagulayan presented a notarized deed of absolute sale, Transfer Certificate of Title (TCT) in her name, and real property tax receipts, all of which supported her claim of ownership.
What does preponderance of evidence mean?	Preponderance of evidence means that the party with the greater weight of evidence prevails. The court must be convinced that the facts asserted are more likely true than not.
Can a registered land title be easily overturned?	No, a registered land title is considered strong evidence of ownership and cannot be easily overturned. It requires compelling proof to the contrary.
What is the Torrens system?	The Torrens system is a land registration system that aims to provide security and stability to land ownership. It operates on the principle that a certificate of title is conclusive evidence of ownership.
What was the annual income of Demetria Pagulayan when she bought the property?	The heirs of Cue alleged that Demetria Pagulayan only had an annual salary of P1,950.00 when she purportedly bought the property, as proof she could not afford it. This was in 1976.

The Supreme Court’s decision in Arjonillo v. Pagulayan serves as a reminder of the importance of presenting solid, admissible evidence when challenging a registered land title. Conjecture and hearsay are insufficient to overcome the security provided by the Torrens system. This case underscores the necessity of diligent preparation and adherence to the rules of evidence in property disputes.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Florencia Arjonillo vs. Demetria Pagulayan, G.R. No. 196074, October 04, 2017