In a dispute over family property, the Supreme Court ruled that a certificate of title obtained through a forged deed does not grant the holder the right to eject co-owners from the property. Even with a Torrens title, if the underlying deed is proven to be a forgery, the titleholder cannot claim exclusive ownership and evict rightful co-heirs. This decision underscores the principle that registration does not validate fraudulent transactions, and the indefeasibility of a Torrens title cannot be used to perpetrate fraud against rightful owners. It reinforces the rights of co-owners to possess and enjoy property inherited from their parents, protecting them from unlawful eviction based on spurious claims of ownership. This case serves as a crucial reminder that the courts prioritize substance over form, especially when dealing with fundamental rights to property ownership and possession within families.

Sibling Squabble: Can a Forged Deed Justify Ejectment from Inherited Land?

The case of Consolacion D. Romero and Rosario S.D. Domingo vs. Engracia D. Singson (G.R. No. 200969, August 3, 2015) revolves around a contentious family property dispute. The petitioners, Consolacion and Rosario Domingo, and the respondent, Engracia Singson, are siblings embroiled in a legal battle over a 223-square meter property in San Juan City. This property originally belonged to their parents, Macario and Felicidad Domingo. After their parents’ death, Engracia presented a new Transfer Certificate of Title (TCT) in her name, claiming ownership based on an ‘Absolute Deed of Sale’ purportedly executed by her deceased parents. This deed became the central point of contention. The petitioners contested the validity of the deed, asserting it was a forgery since their parents were already deceased at the time of its alleged execution.

The legal saga began when Engracia, armed with her TCT, sought to evict her siblings from the property. She filed an unlawful detainer suit, arguing that she was the rightful owner and her siblings’ occupancy was merely tolerated. In response, Consolacion and Rosario challenged the authenticity of the deed of sale and asserted their rights as co-owners of the property, inherited from their parents. The Metropolitan Trial Court (MeTC) initially ruled in favor of Engracia, upholding her right to eject her siblings based on her Torrens title. However, the Regional Trial Court (RTC), on appeal, initially affirmed the MeTC’s decision but later reversed itself, dismissing the ejectment case. The RTC emphasized that the deed of sale was the basis for the transfer and since the vendors were already deceased at the time of execution, the deed was invalid. This reversal prompted Engracia to elevate the case to the Court of Appeals (CA).

The Court of Appeals sided with Engracia, reinstating the MeTC’s decision and emphasizing that the issue in an unlawful detainer case is possession de facto. The CA reasoned that Engracia held a more recently issued certificate of title, granting her a better right to possess the property. However, this decision was not the end of the road. Consolacion and Rosario brought the case to the Supreme Court, raising several key issues. They argued that the ejectment complaint should have been dismissed due to the lack of prior attempts at compromise, as required in disputes between family members. Further, they contended that the issue of ownership was intertwined with the ejectment case, stripping the MeTC of jurisdiction. Finally, they asserted that the CA erred in not recognizing the fraudulent nature of Engracia’s deed of sale and in ruling that their defense constituted a collateral attack on her title.

The Supreme Court granted the petition, reversing the CA’s decision and reinstating the RTC’s order dismissing the ejectment case. The Court’s analysis hinged on the crucial finding that the deed of sale presented by Engracia was a forgery. This determination was pivotal because, under Philippine law, a forged deed is null and void and cannot serve as a valid basis for transferring ownership. The Court cited Borromeo v. Mina, stating that a void contract is “equivalent to nothing; it produces no civil effect; and it does not create, modify or extinguish a juridical relation.”

The Court emphasized that even with a Torrens title, Engracia did not acquire any right or title because of the forged deed. It referenced Heirs of Victorino Sarili v. Lagrosa, explaining that when an instrument is forged, the registered owner does not lose title, and the assignee in the forged deed gains no rights. The Supreme Court also highlighted the principle that a Torrens title does not shield fraudulent transactions, citing Spouses Reyes v. Montemayor:

Insofar as a person who fraudulently obtained a property is concerned, the registration of the property in said person’s name would not be sufficient to vest in him or her the title to the property. A certificate of title merely confirms or records title already existing and vested. The indefeasibility of the Torrens title should not be used as a means to perpetrate fraud against the rightful owner of real property.

Because the deed of sale was invalid, the property remained under the ownership of Macario and Felicidad Domingo. As heirs, Consolacion, Rosario, and Engracia were co-owners of the property through succession. This co-ownership entitled Consolacion and Rosario to exercise all attributes of ownership, including possession. The Court held that Engracia could not exclude them from this right through an ejectment action. The court further discussed the concept of co-ownership, referencing Article 487 of the Civil Code and the case of Abing v. Waeyan:

True it is that under Article 487 of the Civil Code, a co-owner may bring an action for ejectment against a co-owner who takes exclusive possession and asserts exclusive ownership of a common property.

However, because Consolacion and Rosario did not claim exclusive ownership, Engracia’s ejectment case was deemed inappropriate. The Supreme Court clarified that an action to declare the nullity of a void title is not subject to prescription and can be attacked directly or collaterally. Therefore, Consolacion and Rosario were not precluded from questioning the validity of Engracia’s title in the ejectment case. This ruling reaffirms the principle that justice and equity prevail over technicalities when dealing with property rights, especially within family settings.

The practical implications of this decision are significant. It reinforces the protection of property rights for heirs and co-owners against fraudulent claims. It clarifies that a Torrens title obtained through forgery offers no legal advantage and cannot be used to dispossess rightful owners. More broadly, this case underscores the importance of due diligence in property transactions and the need for courts to scrutinize the validity of documents presented as proof of ownership, especially when fraud is alleged. By prioritizing substance over form, the Supreme Court ensured that the principles of equity and justice are upheld in property disputes, safeguarding the rights of those who rightfully inherit property.

FAQs

What was the key issue in this case?	The key issue was whether a person holding a Torrens title obtained through a forged deed of sale could eject co-owners from a property inherited from their parents.
What is a Torrens title?	A Torrens title is a certificate of ownership issued under the Torrens system, which is a land registration system used in the Philippines to guarantee the integrity of land titles. It is considered evidence of indefeasible title to the property.
What happens if a deed of sale is forged?	If a deed of sale is forged, it is considered null and void, meaning it has no legal effect and cannot transfer ownership of the property. Any title obtained through a forged deed is also invalid.
What are the rights of co-owners of a property?	Co-owners have the right to possess, use, and enjoy the property in common. They can also bring an action for ejectment against a co-owner who takes exclusive possession and asserts exclusive ownership of the property.
What is an action for unlawful detainer?	An action for unlawful detainer is a legal proceeding to recover possession of real property from someone who initially had lawful possession but whose right to possess has expired or terminated.
Can a Torrens title be challenged in court?	Yes, a Torrens title can be challenged in court, especially if it was obtained through fraud, forgery, or other illegal means. The challenge must be made in a direct action for that purpose.
What is the effect of registration of a property obtained through fraud?	Registration of a property obtained through fraud does not validate the fraudulent transaction. The person in whose name the property is registered holds it as a mere trustee for the rightful owner.
What is the significance of proving that the deed of sale was a forgery in this case?	Proving that the deed of sale was a forgery was crucial because it invalidated Engracia’s claim of ownership based on the deed. Consequently, her title was deemed invalid, and she had no right to eject her siblings from the property.
What does the court mean by direct vs collateral attack on a title?	A direct attack on a title is when the main purpose of the action is to challenge the validity of the title. A collateral attack is when the challenge to the validity of the title is incidental to another cause of action.

The Supreme Court’s decision in this case safeguards the rights of rightful property owners against fraudulent claims and reinforces the principle that a Torrens title is not an absolute shield against injustice. It underscores the importance of verifying the validity of documents in property transactions and upholds the rights of co-owners to inherit and possess property without fear of unlawful eviction based on spurious claims of 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: CONSOLACION D. ROMERO AND ROSARIO S.D. DOMINGO, VS. ENGRACIA D. SINGSON, G.R. No. 200969, August 03, 2015