Case Digest (G.R. No. 161034)
Facts:
This case commenced with the petition filed by respondents Trinidad Salazar and Aniceta Salazar to cancel certain annotations on Original Certificate of Title (OCT) No. 40287 registered under the names of spouses Juan Soriano and Vicenta Macaraeg, who passed away without any issue. On November 19, 1985, the Salazars contended that Entry Nos. 19756 and 20102 on the title were invalid, citing the absence of a consolidation of rights in the Registry of Deeds (RD) of Tarlac to support their claims. They also noted that Transfer Certificate of Title (TCT) No. 9297, which supposedly canceled OCT No. 40287, was non-existent as per an official certification from the RD. On October 21, 1986, RTC Branch 63 granted the Salazars' petition to cancel Entry No. 20102, although no respondents were mentioned in this order. Following this, further motions were filed by the Salazars seeking compliance regarding the titles issued under the aforementioned entries, resulting in an order directing
Case Digest (G.R. No. 161034)
Facts:
- On November 19, 1985, respondents Trinidad Salazar and Aniceta Salazar filed a petition for cancellation of entries annotated at the back of Original Certificate of Title (OCT) No. 40287, registered in the names of spouses Juan Soriano and Vicenta Macaraeg, who died without issue.
- The Salazars targeted Entry Nos. 19756 and 20102 on the OCT, contending that these entries were void because no consolidation of rights was recorded in the Registry of Deeds (RD) of Tarlac to support them. They also alleged that Transfer Certificate of Title (TCT) No. 9297—purportedly cancelling the OCT—was non-existent as per the RD’s certification.
Initiation of the Controversy
- On October 21, 1986, RTC Branch 63 of Tarlac granted the petition and issued an order to cancel Entry No. 20102.
- Subsequently, the Salazars filed an urgent motion requesting the RD to recall all titles issued under Entries Nos. 19756 and 20102 and to cancel corresponding tax declarations; this motion was granted on November 7, 1986.
- A subsequent motion by the Salazars on November 20, 1986 sought to compel the owners of the affected property to appear and show cause why their titles should not be cancelled.
Early Proceedings and Orders
- On October 20, 1987, the Salazars moved for the RD to comply with its earlier order; the RD, however, argued that doing so would invalidate the basis for the issuance of TCT No. 9297 and would deprive registered owners of due process.
- The RTC, after a period of reconsideration and en consulta, eventually directed the RD of Tarlac to comply with the orders following threats of contempt.
- On March 7, 1989, OCT No. 40287 was reconstituted and TCT No. 219121 was issued in the names of the Salazars (without the two contested entries).
Developments in the Registration Process
- At the issuance of TCT No. 219121, petitioners—along with other subsequent purchasers (27 titleholders in all)—filed a formal written comment asserting that they had acquired their titles in good faith and for value.
- The oppositors argued that the lower court, acting effectively as a land registration court, lacked jurisdiction over issues of ownership.
Intervention of Subsequent Parties and Opposition
- The Salazars, unsatisfied with earlier proceedings, later filed a complaint for quieting of title before RTC Branch 64, impleading petitioners and additional individuals claiming ownership.
- The complaint asserted that while TCT No. 219121 had been issued in the Salazars’ names, previous TCTs and tax declarations had not been properly cancelled or revoked, thereby prejudicing the complainants’ rights.
- Defendants, including the Macaraegs and petitioners, responded by challenging the jurisdiction of the lower courts, asserting that the ex parte petition was void, and contending that even if the Salazars had any rights, such rights had been barred by prescription or were collateral attacks on a Torrens title.
Quieting of Title Complaint and Subsequent Answers
- On December 20, 2000, RTC Branch 64 dismissed the quieting of title complaint for the Salazars, faulting them for failing to present proof of their status as heirs of Juan Soriano. The court also declared TCT No. 219121 null and void and affirmed TCT No. 9297 as valid.
- The Salazars appealed the RTC decision to the Court of Appeals (CA), which reversed the RTC Branch 64 ruling by holding that the orders of RTC Branch 63 were final and binding due to res judicata, and that the lack of personal notice in this land registration proceeding did not vitiate the court’s jurisdiction.
Further Litigation in the Lower Courts
- Petitioners subsequently filed a petition for review on certiorari challenging the CA’s ruling.
- Central to the dispute was whether the Salazars’ initial proceedings, taken as quasi in rem actions, were valid given that they failed to implead indispensable parties—namely, the heirs of Juan Soriano and those who acquired the property subsequently.
- The Supreme Court evaluated whether the orders stemming from void proceedings could bind subsequent title holders and decided that, because the Salazars did not implement necessary parties in the earlier proceedings, the orders in question never acquired finality.
Petition for Review and the Supreme Court’s Intervention
Issue:
- Whether the ex parte petition for cancellation of entries on TROENS titles, which are procured via quasi in rem proceedings, can validly be instituted without the personal involvement or proper impleading of all indispensable parties.
- Whether the failure to include the heirs of Juan Soriano or the successors-in-interest disqualifies the proceedings from commandeering finality under the doctrine of res judicata.
Jurisdiction and Nature of Proceedings
- Whether a void judicial order, which did not purchase finality due to a lack of authority over non-impleaded parties, can have a binding effect on the rights and interests of subsequent purchasers under the Torrens system.
- Whether the 'collateral attack' on a Torrens certificate of title may be entertained in an action for quieting of title.
Validity and Effect of Void Orders
- Whether the long period of inaction by the Salazars (spanning over 30 years) and their failure to timely assert their rights effectively bars or deems stale their claim under the doctrines of prescription and laches.
The Role of Prescription and Laches
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)