The Supreme Court addressed a protracted land dispute, emphasizing the rights of a buyer who purchased land before the issuance of the final decree in a land registration case. The Court clarified the proper procedures for asserting those rights and rectifying errors in certificates of title. This case highlights the importance of diligently pursuing one’s claims in land registration proceedings to protect property rights, particularly when a sale occurs prior to the issuance of the final decree.

From Promise to Protraction: Can a Prior Sale Trump a Registered Title?

The story began with Alfonso Sandoval and Roman Ozaeta, Jr. applying for land registration in 1960. The Court of First Instance (CFI) of Rizal adjudicated the land in their favor in 1966. However, before the actual issuance of the decrees of registration, Sandoval and Ozaeta sold the land to Eugenio Lopez in 1970. In the Deed of Absolute Sale, the sellers committed to ensuring the titles would be issued in Lopez’s name. For years, this commitment went unfulfilled. After Lopez passed away, his heirs stepped in, filing motions to recognize the sale. Amidst these motions, decrees and Original Certificates of Title (OCTs) were issued in the names of Sandoval and Ozaeta, leading to a legal battle over who rightfully owned the land.

The Lopez heirs argued that they had legal standing to question the titles issued in the names of Sandoval and Ozaeta, and that the issuance of these titles was irregular. They sought to have the titles annulled and new ones issued in their names. On the other hand, the court considered whether the heirs could attack the title and the propriety of an ex parte writ of possession. The central issue was whether the Lopez heirs could assert their rights as buyers of the land, despite the titles being registered in the names of the original applicants.

The Supreme Court navigated these complex issues, first addressing the standing of the Lopez heirs in the land registration proceedings. The Court acknowledged that while the Lopez heirs did not automatically become parties to the land registration case, they were entitled to certain remedies under Section 22 of Presidential Decree No. 1529. This provision allows for the recognition of dealings with land pending original registration. The Court quoted Mendoza v. Court of Appeals to emphasize this point:

It is clear from the above-quoted provision that the law expressly allows the land, subject matter of an application for registration, to be ‘dealt with’, i.e., to be disposed of or encumbered during the interval of time between the filing of the application and the issuance of the decree of title, and to have the instruments embodying such disposition or encumbrance presented to the registration court by the ‘interested party’ for the court to either ‘order such land registered subject to the encumbrance created by said instruments, or order the decree of registration issued in the name of the buyer or of the person to whom the property has been conveyed by said instruments.

Building on this principle, the Court determined that the Lopez heirs should have availed themselves of Section 108 of Presidential Decree No. 1529 to correct the errors in the certificates of title. This section allows for the amendment and alteration of certificates of title when new interests have arisen or errors have been made. The Court clarified that the land registration court did not necessarily lose jurisdiction over the case, even with the issuance of the decrees of registration.

The Court differentiated this case from others requiring separate civil actions, emphasizing that the present controversy was a continuation of the original land registration proceedings. It noted the land registration court was already hearing the Lopez heirs’ motion when the Land Registration Authority (LRA) issued the decrees and titles with patent errors on their face. The Court cited Vda. de Arceo v. Court of Appeals to support the expanded jurisdiction of land registration courts, particularly where parties have acquiesced to the court’s determination of controversial issues.

We have held that under Section 2 of the Property Registration Decree, the jurisdiction of the Regional Trial Court, sitting as a land registration court, is no longer as circumscribed as it was under Act No. 496, the former land registration law…The amendment was ‘[a]imed at avoiding multiplicity of suits, the change has simplified registration proceedings by conferring upon the required trial courts the authority to act not only on applications for ‘original registration’ but also ‘over all petitions filed after original registration of title, with power to hear and determine all questions arising from such applications or petitions.’

The Court addressed the issue of the Sandoval heirs being bound by the Deed of Absolute Sale, emphasizing the general rule in Article 1311 of the Civil Code, which states that heirs are bound by the contracts entered into by their predecessors. This principle was highlighted in Santos v. Lumbac, where the Court stated:

It is clear from [Article 1311 of the Civil Code] that whatever rights and obligations the decedent have over the property were transmitted to the heirs by way of succession… Thus, the heirs cannot escape the legal consequence of a transaction entered into by their predecessor-in-interest because they have inherited the property subject to the liability affecting their common ancestor.

Regarding the writ of possession, the Court found it improperly issued. While a writ of possession is generally available to a successful litigant in a land registration case, it ceases to be a ministerial duty when there are actual possessors of the property claiming ownership. According to Article 433 of the Civil Code, actual possession under a claim of ownership raises a disputable presumption of ownership, requiring the true owner to resort to judicial process to recover the property.

The Court also questioned the authority of Imelda Rivera to file the petition for the writ of possession, finding her Special Power of Attorney (SPA) insufficient. Citing Angeles v. Philippine National Railways, the Court emphasized that a power of attorney must be strictly construed and pursued, granting only the powers specified therein.

FAQs

What was the key issue in this case?	The central issue was whether the Lopez heirs could assert their rights as buyers of land based on a Deed of Absolute Sale executed before the issuance of the final decree of registration and Original Certificates of Title (OCTs) in the names of the original applicants, Sandoval and Ozaeta.
What is Section 22 of Presidential Decree No. 1529?	Section 22 of Presidential Decree No. 1529 allows for the recognition of dealings with land pending original registration, permitting the court to order the land registered subject to the conveyance or issue the decree of registration in the name of the buyer.
What is the significance of Section 108 of Presidential Decree No. 1529?	Section 108 of Presidential Decree No. 1529 authorizes a person with an interest in registered property to seek the amendment or alteration of a certificate of title if new interests have arisen or errors have been made in the certificate. This could include correcting errors in dates or names on a title.
Are heirs bound by contracts entered into by their predecessors-in-interest?	Yes, as a general rule, Article 1311 of the Civil Code states that heirs are bound by the contracts entered into by their predecessors-in-interest, meaning they inherit both the rights and obligations of the deceased, limited to the value of the inheritance.
What is a writ of possession, and when is it appropriately issued?	A writ of possession is a court order directing the sheriff to place a successful litigant in possession of a property; however, it is not a ministerial duty of the court when there are actual possessors claiming ownership of the property.
When can a land registration court assume jurisdiction over ownership disputes?	A land registration court can assume jurisdiction over ownership disputes when the parties mutually agree or acquiesce in submitting the issue, when they have been given full opportunity to present evidence, and when the issue is inextricably tied to the right of registration.
What happens if a property description in a Special Power of Attorney (SPA) doesn’t match the actual property?	If the property description in an SPA does not match the actual property, it raises serious questions about the agent’s authority to act on behalf of the principal regarding that specific property, and the SPA must be strictly construed.
What actions are required when errors are discovered on Original Certificates of Title?	When errors are discovered on Original Certificates of Title, such as incorrect dates of issuance or entry, proceedings under Section 108 of Presidential Decree No. 1529 are proper to rectify these errors, ensuring the certificates accurately reflect the required legal information.

This case underscores the importance of vigilance in land registration proceedings and the availability of legal remedies to protect property rights. The Supreme Court’s decision clarifies the rights of purchasers who buy land before the issuance of the final decree and provides a pathway for correcting errors in certificates of title. It reaffirms that the land registration court retains jurisdiction to address incidents and errors, even after the initial decree has been issued, to ensure justice and equity in land ownership.

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: Heirs of Eugenio Lopez, Sr. vs. Francisco Querubin, G.R. No. 164092, March 18, 2015