Title
Adviento vs. Heirs of Alvarez
Case
G.R. No. 150844
Decision Date
Aug 20, 2008
Dispute over 228 sqm land in Naga City; Alvarez claimed ownership, Gaya held registered title. Courts ruled fraud in Gaya's title, upheld Alvarez's heirs' claim, annulled Gaya's title, awarded damages.
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Case Digest (G.R. No. 150844)

Facts:

  1. Parties and Property in Dispute:

    • The case involves a parcel of land with an area of 228 square meters located in Naga City. The original plaintiff, Miguel Alvarez (substituted by his heirs after his death), claimed ownership of the land, while Lydia Gaya, the defendant, asserted her ownership through a registered title.
    • The land was originally part of Lot No. 1696 of the Cadastral Survey of Naga and was later subdivided into Lot No. 3164.
  2. Alvarez’s Claims:

    • Miguel Alvarez alleged continuous, exclusive, and notorious possession of the land, including its buildings.
    • He claimed that Lydia Gaya fraudulently obtained Original Certificate of Title (OCT) No. 338 without notifying him, despite his lawful occupation and ownership.
    • Alvarez sought reconveyance of the land, damages, and attorney’s fees.
  3. Gaya’s Defense:

    • Lydia Gaya countered that she had been in peaceful and continuous possession of the land since 1936.
    • She asserted that she acquired an imperfect title, which was confirmed by the Cadastral Court in 1966, leading to the issuance of OCT No. 338 in 1968.
    • She argued that Alvarez’s claim was barred by the statute of limitations and that her title was indefeasible.
  4. Intervention by Ceferino Adviento:

    • Ceferino Adviento, the petitioner, intervened, claiming he purchased part of the land from Fidel Cu, who had bought it from Lydia Gaya.
    • Adviento alleged that Alvarez’s building encroached on his property and sought damages.
  5. Trial Court and Court of Appeals Rulings:

    • The Regional Trial Court (RTC) ruled in favor of Alvarez’s heirs, annulling OCT No. 338 and subsequent titles (TCT 13200 and TCT 15201) in so far as they covered the disputed 228 square meters.
    • The Court of Appeals (CA) affirmed the RTC’s decision.

Issue:

  1. Whether the Court of Appeals erred in failing to rule that riparian ownership ceases when a road borders a stream or river, and any accretion does not belong to the owner.
  2. Whether the Court of Appeals erred in not holding that the judicial admission of Miguel Alvarez regarding Lydia Gaya’s title controlled the subsequent proceedings.
  3. Whether the Court of Appeals erred in not recognizing the regularity, validity, and conclusiveness of the land registration decree in favor of Lydia Gaya.
  4. Whether the Court of Appeals erred in not dismissing the case due to the completeness and determination of title in favor of Lydia Gaya and subsequently Ceferino Adviento.
  5. Whether the Court of Appeals erred in awarding attorney’s fees to Alvarez’s heirs despite the absence of fraud.

Ruling:

The Supreme Court denied the petition for review on certiorari and affirmed the decisions of the RTC and CA. The Court held:

  1. The issue of riparian ownership was raised for the first time on appeal and could not be entertained, as the Supreme Court is not a trier of facts.
  2. The judicial admission regarding Lydia Gaya’s title did not preclude the need for proof of ownership, as the facts related to the admission were not indisputable.
  3. The land registration decree in favor of Lydia Gaya was obtained through fraud, as Alvarez was not notified of the proceedings, violating due process.
  4. The RTC and CA were not bound by the land registration decree, especially when fraud was alleged and proven.
  5. The award of attorney’s fees was justified, as the fraud committed by Lydia Gaya warranted such damages.

Ratio:

  1. Fraud in Land Registration:

    • The lack of notice to Miguel Alvarez in the land registration proceedings constituted extrinsic fraud, which deprived him of the opportunity to present his claim.
    • Fraud vitiates the land registration decree, and the courts are not bound by such a decree when fraud is proven.
  2. Judicial Admissions and Proof of Ownership:

    • Judicial admissions regarding the existence of a title do not automatically establish ownership. The facts underlying the admission must still be proven.
  3. Innocent Purchaser for Value:

    • Ceferino Adviento could not claim to be an innocent purchaser for value, as he had knowledge of the pending case (lis pendens) and the defects in the title when he purchased the land.
  4. Due Process in Land Registration:

    • The Land Registration Act (Act No. 496) requires notice to all occupants and adjoining owners. The failure to notify Alvarez violated his right to due process.
  5. Finality of Land Titles:

    • A land registration decree is not absolute and can be annulled if obtained through fraud. The courts have the authority to review and annul such decrees.

Conclusion:

The Supreme Court upheld the rulings of the RTC and CA, emphasizing that fraud in land registration proceedings invalidates the resulting title. The lack of notice to the rightful owner, Miguel Alvarez, and the subsequent fraudulent actions of Lydia Gaya justified the annulment of her title and the award of damages to Alvarez’s heirs.


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