The Supreme Court has affirmed that in ejectment cases, the registered owner of a property has the right to possess it, prioritizing registered titles over unregistered claims. This ruling underscores the importance of having property ownership formally recorded, as it provides a strong legal basis for asserting one’s rights. Even if someone else is physically occupying the property, the registered owner can legally demand that they leave.

Possession vs. Ownership: Who Prevails in This Land Dispute?

This case revolves around a dispute over a parcel of land and a house in Camalig, Albay. Anita Nieves, the registered owner, filed an ejectment suit against Spouses Ida and Jose Beltran, who claimed ownership based on an unregistered deed of sale purportedly made by Nieves to Ida’s father, Gaston Nieves. The central legal question is: In an ejectment case, who has the better right of possession – the registered owner or those claiming ownership through an unregistered document?

Nieves asserted her rights as the registered owner, presenting her Transfer Certificate of Title (TCT). The spouses Beltran countered that Nieves sold the property to Gaston Nieves, Milagros’ father, and presented an unregistered deed of sale as evidence. They argued their possession was not based on Nieves’ tolerance but as heirs of Gaston, who they claimed owned the property. The Municipal Circuit Trial Court (MCTC) initially ruled in favor of the spouses Beltran, giving weight to the unregistered deed of sale. However, the Regional Trial Court (RTC) affirmed the MCTC’s decision but clarified that it did not delve into the issue of just title, focusing solely on possession.

On appeal, the Court of Appeals (CA) reversed the RTC’s decision, siding with Nieves. The CA emphasized that a certificate of title is conclusive evidence of ownership and that the tax declarations presented by the spouses Beltran were merely indicators of possession, not ownership. The appellate court also found that the ejectment suit was filed within the one-year prescriptive period. The spouses Beltran then elevated the case to the Supreme Court, arguing that the CA erred in prioritizing the photocopy of Nieves’ TCT and disregarding their claim based on the unregistered deed of sale.

The Supreme Court (SC) affirmed the CA’s decision, reiterating the principle that in ejectment cases, the primary issue is physical possession (possession de facto), not legal ownership (possession de jure). However, the Court acknowledged that the issue of ownership may be provisionally ruled upon to determine who has the better right to possess the property. The SC held that Nieves, as the registered owner, has a superior right of possession compared to the spouses Beltran, whose claim rested on an unregistered deed of sale.

The Court emphasized that any question regarding the validity of Nieves’ title must be raised in a separate action specifically instituted for that purpose, and that a certificate of title cannot be collaterally attacked in an ejectment case. According to Section 48 of Presidential Decree No. 1529 (P.D. No. 1529) or the Property Registration Decree, a certificate of title shall not be subject to collateral attack:

“SECTION 48. Certificate not subject to collateral attack. – A certificate of title shall not be subject to collateral attack. It cannot be altered, modified, or cancelled except in a direct proceeding in accordance with law.”

The Supreme Court also cited previous rulings, such as Spouses Apostol v. Court of Appeals, which affirmed the right of registered owners to possess their property from the time the title was issued. The Supreme Court also referenced the case of Calubayan, et al. v. Pascual, where it was held that a person occupying land with the owner’s tolerance implicitly promises to vacate upon demand, and failure to do so warrants an ejectment action. In summary, the High Tribunal found that whatever possessory right the spouses Beltran claimed could not stand against the rights of Nieves as registered owner. Ultimately, the Court ruled that Nieves, as the registered owner, was entitled to the possession of the property. This decision highlights the significance of property registration in the Philippines and protects the rights of registered owners.

FAQs

What was the central issue in this case?	The central issue was determining who had the better right of possession over a property in an ejectment case: the registered owner or those claiming ownership through an unregistered deed of sale. The Supreme Court prioritized the rights of the registered owner.
What is an ejectment case?	An ejectment case is a legal action filed to recover the physical possession of real property from someone who is unlawfully occupying it. It is a summary proceeding designed to quickly resolve possession disputes.
What is the significance of a Transfer Certificate of Title (TCT)?	A TCT is a document issued by the Registry of Deeds that proves ownership of a parcel of land. It serves as the primary evidence of ownership and provides strong legal protection to the registered owner.
What is the effect of an unregistered deed of sale?	An unregistered deed of sale, while valid between the parties, does not bind third persons. It does not automatically transfer ownership and cannot defeat the rights of a registered owner.
Can ownership be determined in an ejectment case?	While the main issue in an ejectment case is possession, the court may provisionally rule on ownership to determine who has the better right of possession. However, this ruling is not final and does not bar a separate action to determine ownership.
What is a collateral attack on a title?	A collateral attack on a title is an attempt to challenge the validity of a certificate of title in a proceeding where the primary issue is not the validity of the title itself. Such attacks are generally not allowed.
What is the prescriptive period for filing an ejectment case?	For unlawful detainer, the action must be filed within one year from the date of the last demand to vacate the property. Failure to file within this period may result in the dismissal of the case.
What happens if the occupant claims ownership of the property?	Even if the occupant claims ownership, the registered owner generally has the better right of possession in an ejectment case. The occupant may need to file a separate action to prove their claim of ownership.

This case clarifies the importance of registering property titles in the Philippines. It provides a strong legal basis for asserting one’s rights as a property owner. The ruling serves as a reminder that physical possession alone is not enough to defeat the rights of a registered owner.

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: Spouses Ida AKA “Milagros” Nieves Beltran and Jose Beltran v. Anita R. Nieves, G.R. No. 175561, October 20, 2010