When two parties claim ownership of the same piece of land based on different certificates of title, the Supreme Court has provided a clear framework for determining who has the superior right. In Encinas v. National Bookstore, the Court reiterates the principle that the validity of a reconstituted title is contingent upon the absence of any other existing valid title for the same property. Furthermore, the Court emphasized the importance of tracing the origin and validity of each title to resolve conflicting claims, prioritizing the earlier registered title if it is proven to be authentic and untainted by fraud or irregularity. This ruling offers clarity and protection to legitimate landowners against potentially dubious claims arising from reconstituted titles.

Clash of Titles: Unveiling Ownership Disputes in Quezon City Real Estate

This case originated from a dispute over a parcel of land located at the corner of EDSA and Aurora Boulevard in Quezon City. Both Memoria G. Encinas and National Bookstore, Inc. (NBS) claimed ownership based on their respective transfer certificates of title (TCTs). Encinas relied on a reconstituted TCT, while NBS held an original TCT that was not affected by a fire that razed the Registry of Deeds. The core legal question was simple: Which title should prevail when two certificates cover the same land?

The facts revealed that the land was initially part of a larger estate owned by Valentin Afable and Eugenio Evangelista. The Evangelista portion, designated as Lot 4-B-2-B, was eventually transferred to the Heirs of Simeon Evangelista. The Heirs subsequently sold the land, with a mortgage, to the spouses Nereo and Gloria Paculdo. When the Paculdos defaulted on the mortgage, the Heirs foreclosed and reacquired the property, eventually selling a 7,465-square-meter portion to NBS in 1983. NBS took possession, paid taxes, and obtained TCT No. 300861.

In 1994, Memoria G. Encinas filed for administrative reconstitution of her allegedly burned title, TCT No. 179854, presenting a tax declaration and a certification of tax payments. The Land Registration Authority (LRA) initially granted the reconstitution, issuing TCT No. RT-103022 in Encinas’ name. Later, NBS discovered the overlapping claims and contested Encinas’ title. The LRA eventually set aside the reconstitution order for Encinas’ title following its investigation.

The Regional Trial Court (RTC) initially ruled in favor of NBS, emphasizing that a reconstituted title is only valid if no other certificate exists and if the original title is lost. Because NBS had the original TCT No. 300861, which was not burned, and could trace its ownership, the RTC initially upheld NBS’s claim. However, on reconsideration, the RTC reversed itself, favoring Encinas, reasoning that her earlier title (August 25, 1972) served as constructive notice to NBS (whose title was issued on June 6, 1983). The RTC also questioned the origin of NBS’s title, noting an error in the General Land Registration Office (GLRO) record number.

On appeal, the Court of Appeals (CA) reinstated the RTC’s original decision, favoring NBS. The appellate court found that NBS had adequately demonstrated the chain of ownership and possession, while Encinas failed to prove how she acquired her title. The CA also dismissed the GLRO record number error as a mere typographical mistake, deferring to the technical description that correctly identified the land’s location. The court gives great weight to original titles over claims of reconstituted titles, as evidence of ownership are often more trustworthy.

The Supreme Court affirmed the Court of Appeals’ decision. The Court reiterated that in civil cases, the party with the burden of proof must establish their case by a preponderance of evidence. NBS successfully demonstrated its ownership through documented transactions and tax payments, thus meeting the burden of proof required. “Preponderance of evidence” is the weight, credit, and value of the aggregate evidence on either side and is usually considered to be synonymous with the term “greater weight of the evidence” or “greater weight of the credible evidence.” Preponderance of evidence is a phrase which, in the last analysis, means probability of the truth.  It is evidence which is more convincing to the court as worthy of belief than that which is offered in opposition thereto.

Conversely, Encinas failed to adequately prove her claim, relying primarily on the reconstituted title and failing to explain how she acquired ownership. The Court found the evidence of NBS was more credible than the evidence presented by Encinas. Although petitioners submitted their TCT they never demonstrated the means they used to obtain their original claim over the title. The Court ruled they cannot rely on their claims to the title when they cannot give supporting claims.

The Court also addressed the alleged defect in NBS’s title—the incorrect GLRO record number—determining it to be a minor clerical error that did not invalidate the title. The technical description of the property was determined by the Court to be the controlling aspect that outweighed the GLRO number’s clerical error. This demonstrates a focus on what the Court determined to be what was more important, and the clerical GLRO error could not cause prejudice to the NBS claim over ownership.

FAQs

What was the key issue in this case?	The central issue was determining the rightful owner of a parcel of land claimed by two parties, one holding a reconstituted title and the other an original, existing title. The court had to decide which title would prevail, based on evidence of ownership and the validity of the titles themselves.
What is a reconstituted title?	A reconstituted title is a replacement title issued when the original land title has been lost or destroyed, typically through a judicial or administrative process. It aims to restore the record of ownership based on available evidence.
What happens when there are overlapping land titles?	When two titles cover the same land, courts generally prioritize the earlier registered title if it’s proven valid. The court may order one of the titles cancelled.
What does it mean to have a “preponderance of evidence”?	Preponderance of evidence means that the evidence presented by one party is more convincing and credible than the evidence presented by the other party. It is the standard of proof used in most civil cases.
Why did the Supreme Court favor National Bookstore’s title?	The Supreme Court favored National Bookstore because it had a valid, original title that was not affected by the fire, and could trace its ownership back to the original owners. Encinas failed to demonstrate how she came to possess the title to the land.
What significance did the GLRO record number have in the case?	The GLRO record number initially raised concerns about the validity of National Bookstore’s title. The court ultimately dismissed the inconsistency as a minor typographical error that did not invalidate the title, the most important consideration was given to the technical description of the land.
What is the practical effect of this ruling?	This ruling reinforces the importance of carefully tracing the origins of land titles and maintaining accurate records. It also clarifies that reconstituted titles are subordinate to original, existing titles when there are conflicting claims, especially if the proper acquisition can’t be proven.
What if the technical description of the property did not align with the proper land?	The Encinas title did not refer to Lot 4-B-2-B-2, instead it claimed Lot 2-E-2 plan SWO-16797 and this was definitely not the correct property according to the CA.

In summary, the Supreme Court’s decision in Encinas v. National Bookstore underscores the importance of due diligence in land transactions and reaffirms the principle that a valid, existing title generally prevails over a reconstituted one, especially when the latter’s origins are questionable. By prioritizing original titles and emphasizing the need for clear evidence of ownership, the Court protects the rights of legitimate landowners and promotes stability in real estate transactions.

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: Memoria G. Encinas and Adolfo A. Balboa vs. National Bookstore, Inc., G.R. No. 162704, November 19, 2004