In Supapo v. Spouses De Jesus, the Supreme Court reaffirmed that a Torrens title is indefeasible and imprescriptible, meaning that ownership rights cannot be lost through adverse possession by another party, regardless of how long they occupy the land. This decision underscores the security and reliability of the Torrens system in the Philippines, ensuring that registered landowners can recover possession of their property even after extended periods of unauthorized occupation. The ruling clarifies the interplay between property rights, land registration, and the limitations of acquisitive prescription.

Squatters vs. Titleholders: Can Possession Trump a Torrens Title?

Esperanza Supapo and her late husband, Romeo, held a Transfer Certificate of Title (TCT) for a parcel of land in Quezon City. However, they discovered that Spouses Roberto and Susan De Jesus, along with Macario Bernardo, had built houses on their property without permission. This prompted the Supapos to file an accion publiciana, an action to recover the right of possession, against the occupants. The case navigated through various courts, with conflicting decisions on jurisdiction, prescription, and the impact of a prior criminal case. Ultimately, the Supreme Court addressed the core question: Can squatters acquire rights over land covered by a Torrens title simply through long-term possession?

The Supreme Court emphasized that an accion publiciana is a suit to determine the better right of possession, independent of title. While the Supapos based their claim on ownership, the Court clarified that it could examine ownership to resolve the possession issue, but this would not constitute a final determination of ownership. The Court highlighted the importance of determining the appropriate court jurisdiction based on the assessed value of the property. Citing Batas Pambansa Bilang 129 and Republic Act (RA) No. 7691, the Court noted that Metropolitan Trial Courts (MeTC) have jurisdiction over cases involving possession of real property in Metro Manila where the assessed value does not exceed P50,000.00. Since the assessed value of the Supapos’ land was P39,980.00, the MeTC of Caloocan properly acquired jurisdiction.

A central point of contention was whether the Supapos’ claim had prescribed, given that they filed the accion publiciana more than ten years after the occupants began their unauthorized possession. The occupants invoked Article 555 of the Civil Code, which outlines how a possessor may lose possession. The Supreme Court firmly rejected this argument, citing the indefeasibility of a Torrens title. The Court quoted Section 47 of Presidential Decree (PD) No. 1529, also known as the Land Registration Act:

Section 47. Registered land not subject to prescriptions. No title to registered land in derogation of the title of the registered owner shall be acquired by prescription or adverse possession.

The Court emphasized that lands covered by a Torrens title cannot be acquired through prescription or adverse possession. This principle is crucial for maintaining the integrity of the Torrens system, which aims to provide certainty and stability in land ownership. The Court further explained that the right to possess and occupy land is a direct consequence of ownership, and a titleholder has the right to eject any illegal occupants.

The respondents also raised the defense of laches, arguing that the Supapos had delayed unreasonably in asserting their rights. The Court dismissed this argument, stating that laches must be proven with evidence and that the Supapos’ actions, such as bringing the dispute before the Lupon, initiating a criminal complaint, and filing the accion publiciana, demonstrated their intent to recover the property. Moreover, the Supreme Court underscored the policy behind the Torrens system, stating:

The Government has adopted the Torrens system due to its being the most effective measure to guarantee the integrity of land titles and to protect their indefeasibility once the claim of ownership is established and recognized. If a person purchases a piece of land on the assurance that the seller’s title thereto is valid, he should not run the risk of being told later that his acquisition was ineffectual after all, which will not only be unfair to him as the purchaser, but will also erode public confidence in the system and will force land transactions to be attended by complicated and not necessarily conclusive investigations and proof of ownership.

Finally, the respondents argued that the case was barred by res judicata, based on a prior Court of Appeals decision that overturned their conviction under the Anti-Squatting Law. The Supreme Court rejected this argument as well, explaining that res judicata requires identity of parties, subject matter, and cause of action. In this case, the criminal case was prosecuted in the name of the People of the Philippines, while the accion publiciana was filed by the Supapos. The criminal case involved a violation of the Anti-Squatting Law, while the accion publiciana concerned the recovery of possession. Therefore, the requisites of res judicata were not met.

The Court clarified that its ruling was limited to the issue of possession and did not constitute a final determination of ownership. This means that parties or third persons could still file a separate action to determine the issue of ownership. In conclusion, the Supreme Court granted the petition, reversing the Court of Appeals’ decision and upholding the indefeasibility of the Supapos’ Torrens title.

FAQs

What is an accion publiciana?	An accion publiciana is an action to recover the right of possession of a real property, filed when dispossession has lasted longer than one year. It aims to determine who has the better right to possess, independent of the actual title to the property.
What is a Torrens title?	A Torrens title is a certificate of ownership issued under the Torrens system of land registration. It serves as conclusive evidence of ownership and is generally indefeasible, meaning it cannot be easily defeated or challenged.
Can someone acquire ownership of land covered by a Torrens title through squatting?	No, under Philippine law, land covered by a Torrens title cannot be acquired through prescription or adverse possession. This means that squatting on titled land, even for an extended period, does not grant ownership rights to the squatter.
What is res judicata?	Res judicata is a legal principle that prevents a party from relitigating an issue that has already been decided by a court. It applies when there is a final judgment on the merits, rendered by a court with jurisdiction, and there is an identity of parties, subject matter, and cause of action.
What is the significance of the assessed value of the property in this case?	The assessed value of the property determines which court has jurisdiction over the case. Metropolitan Trial Courts (MeTC) have jurisdiction over cases involving possession of real property in Metro Manila where the assessed value does not exceed P50,000.00.
What is the defense of laches?	Laches is the unreasonable delay in asserting a right, which prejudices the opposing party. However, the Supreme Court held that the acts of the Spouses Supapo, such as bringing the dispute before the Lupon, initiating a criminal complaint, and filing the accion publiciana, demonstrated their intent to recover the property.
What was the impact of the repeal of the Anti-Squatting Law on this case?	The repeal of the Anti-Squatting Law led to the dismissal of the criminal case against the respondents. However, it did not affect the Spouses Supapo’s right to file a civil action to recover possession of their property.
Does this decision determine ownership of the land?	No, the Supreme Court clarified that its ruling was limited to the issue of possession and did not constitute a final determination of ownership. Parties or third persons could still file a separate action to determine the issue of ownership.

This ruling serves as a strong reminder of the importance of the Torrens system in protecting property rights in the Philippines. Landowners with registered titles can take legal action to recover possession of their property, even if others have occupied it for an extended period.

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: Esperanza Supapo and The Heirs of Romeo Supapo vs. Spouses Roberto and Susan De Jesus, G.R. No. 198356, April 20, 2015