The Supreme Court has affirmed that a certificate of title cannot be collaterally attacked in a land registration proceeding. This means that if a land title is already registered under someone else’s name, another person cannot simply apply for registration of the same land to challenge the existing title. Instead, they must file a separate legal action specifically for that purpose, such as an action for reconveyance, to directly question the validity of the title.

Deed or Deceit: Can a Land Title be Challenged Through a Registration Application?

This case revolves around a dispute between Josephine Wee and Felicidad Mardo over a parcel of land in Cavite. Wee claimed ownership based on a Deed of Absolute Sale, while Mardo, who had obtained an Original Certificate of Title (OCT) for the land, argued the sale was falsified. Wee’s attempt to register the land in her name was challenged by Mardo, leading to a legal battle that ultimately reached the Supreme Court. The central legal question is whether Wee could challenge Mardo’s already registered title through an application for land registration, or if she needed to pursue a separate action to directly attack the title’s validity.

The Supreme Court anchored its decision on the principle that a certificate of title cannot be subject to collateral attack. This principle is enshrined in Section 48 of Presidential Decree (P.D.) No. 1529, also known as the Property Registration Decree, which explicitly states:

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

This means that the validity of a Torrens title can only be questioned in a direct action specifically filed for that purpose, and not as an incidental issue in another proceeding. The Court emphasized this point by citing Lagrosa v. Court of Appeals, where it was held that the issue of whether a title was procured by falsification or fraud can only be raised in an action expressly instituted for the purpose. This doctrine ensures stability and reliability in land ownership, preventing uncertainty caused by indirect challenges to registered titles.

The implications of this doctrine are significant. The Court pointed out that once a patent is registered and a certificate of title is issued, the land ceases to be part of the public domain and becomes private property. This principle was highlighted in Republic vs. Umali, where the Court stated that once a patent is registered, the Director of Lands loses control and jurisdiction over the property. Moreover, the registered patent becomes as indefeasible as a Torrens title after one year from its issuance, solidifying the owner’s right against future claims.

The petitioner, Wee, argued that the rule on indefeasibility of title should not apply to titles secured by fraud and misrepresentation. She claimed that Mardo fraudulently registered the property after selling a portion of it to her. However, the Court rejected this argument, reiterating that even if fraud or misrepresentation existed, it could not be raised as a collateral attack in a land registration proceeding. The appropriate remedy, according to the Court, would be a separate proceeding for specific performance or reconveyance.

To further clarify, the Supreme Court provided guidance on the remedies available to Wee. Since Wee claimed to have purchased the property from Mardo, she could file an action for specific performance to compel Mardo to comply with the alleged deed of sale. Alternatively, she could file an action for reconveyance, which is an equitable remedy available to a person whose property has been wrongfully registered under the Torrens system in another’s name. As the Supreme Court noted quoting Heirs of Lopez, Sr. v. Hon. Enriquez:

Reconveyance is based on Section 55 of Act No. 496, as amended by Act No. 3322, which states that in all cases of registration procured by fraud the owner may pursue all his legal and equitable remedies against the parties to such fraud, without prejudice, however, to the rights of any innocent holder for value of a certificate of title.

In essence, reconveyance allows the rightful owner to have the land transferred back to them, respecting the decree’s incontrovertibility while addressing the underlying issue of ownership. It’s important to note that while registration provides strong protection, it doesn’t create ownership itself. Registration merely serves as evidence of ownership, and it cannot be used to shield someone who obtained the title through fraud or misrepresentation, especially against the true owner.

This case underscores the importance of understanding the distinction between challenging a certificate of title directly versus collaterally. An action for land registration is not the proper venue to question the validity of an existing title. The legal system provides specific remedies for such situations, ensuring that registered titles are not easily overturned while also providing avenues for those who claim to have been defrauded or wrongly deprived of their property.

The Supreme Court thus denied Wee’s petition, emphasizing that her attempt to register the land under her name constituted a collateral attack on Mardo’s existing title. The Court made it clear that the proper course of action for Wee would be to file a separate proceeding to directly address the validity of Mardo’s title and assert her claim of ownership.

FAQs

What was the key issue in this case?	The key issue was whether Josephine Wee could challenge Felicidad Mardo’s registered land title through an application for land registration, or if she needed to file a separate action to directly attack the title’s validity. The Supreme Court ruled that a collateral attack on a certificate of title is not allowed in a land registration proceeding.
What is a collateral attack on a title?	A collateral attack is an attempt to challenge the validity of a land title in a proceeding where the primary objective is not to question the title itself. It is an indirect attempt to invalidate the title as an incidental matter in another legal action.
What is the proper way to challenge a land title obtained through fraud?	The proper way to challenge a land title obtained through fraud is to file a direct action specifically for that purpose, such as an action for reconveyance or an action to annul the title. This allows the court to directly address the issue of fraud and determine the rightful owner of the property.
What is an action for reconveyance?	An action for reconveyance is a legal remedy available to a person whose property has been wrongfully registered under the Torrens system in another’s name. It seeks to transfer or reconvey the land from the registered owner to the rightful owner, respecting the decree’s incontrovertibility while addressing the underlying issue of ownership.
What is the significance of a Torrens title?	A Torrens title is a certificate of ownership issued under the Torrens system, a system of land registration that aims to provide certainty and security to land ownership. Once registered, the title becomes indefeasible and incontrovertible after one year from the date of issuance, meaning it cannot be easily challenged or overturned.
Can a registered land title be defeated by adverse possession?	No, a registered land title cannot be defeated by adverse possession or prescription. Section 47 of P.D. 1529 explicitly states that no title to registered land in derogation of the registered owner’s title can be acquired through prescription or adverse possession.
What happens if someone fraudulently registers land in their name?	Even if someone fraudulently registers land in their name, the certificate of title they obtain is not automatically invalidated. The aggrieved party must file a direct action to challenge the title and prove the fraud. However, the registration itself does not vest ownership if it was acquired through illegal means.
Does registration of land create ownership?	No, registration of land does not create ownership. It merely serves as evidence of ownership or title over the particular property described in the certificate. Registration does not transfer ownership; it only confirms and protects the existing ownership rights.

In conclusion, the Supreme Court’s decision in this case reinforces the principle of indefeasibility of a Torrens title and the importance of adhering to proper legal procedures when challenging land ownership. While registration provides strong protection to landowners, it does not shield those who obtain titles through fraud or misrepresentation from direct legal challenges.

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: Josephine Wee vs. Felicidad Mardo, G.R. No. 202414, June 04, 2014