Case Digest (G.R. No. 115508)
Facts:
On April 7, 1980, Petra Bilog, assisted by her husband Felipe Bilog, filed a complaint for Recovery of Possession and Ownership with the Regional Trial Court of Agoo, La Union. The case involved an 8,474 square meter parcel of land registered under Transfer Certificate of Title No. T-16109 in her name. Petra alleged that the petitioners, Alejandro Agasen and Fortunata Calonge-Agasen, unlawfully took possession of the property around 1964 or 1965 and appropriated its fruits. Despite her demands for them to vacate, they refused and instead filed a case for Annulment of TCT and/or Reconveyance with Damages, which was dismissed on February 12, 1980. In her complaint, Petra sought a declaration of ownership, possession of the land, and damages amounting to P300,000.00 for attorney's fees, P2,000.00 for litigation expenses, P60,000.00 for the value of the land's produce from 1965 until the filing of the case, and P4,000.00 annually until the case's termination.
In the...
Case Digest (G.R. No. 115508)
Facts:
Ownership Claim: On April 7, 1980, private respondent Petra Bilog, assisted by her husband Felipe Bilog, filed a complaint for Recovery of Possession and Ownership over an 8,474 square meter parcel of land registered in her name under Transfer Certificate of Title No. T-16109. She alleged that petitioners Alejandro Agasen and Fortunata Calonge-Agasen had taken possession of the land since 1964 or 1965, appropriated its fruits, and refused to vacate despite demands.
Petitioners' Defense: Petitioners claimed ownership of the land through two transactions: (a) a sale of 1,785 square meters by Leonora Calonge (Fortunata's sister) and (b) a sale of 6,717.50 square meters by Petra Bilog on June 24, 1968, via a notarized Partition with Sale. They asserted continuous possession of the land since the transactions and built a house on it.
Lower Court Ruling: On November 19, 1984, the Regional Trial Court ruled in favor of petitioners, declaring Petra Bilog's title null and void.
Court of Appeals Decision: The Court of Appeals reversed the lower court's decision, declaring Petra Bilog the true owner and ordering petitioners to turn over the land.
Petitioners' Appeal: Petitioners filed a petition for review, arguing that the Court of Appeals erred in invalidating the Deed of Partition with Sale and the Deed of Absolute Sale, among other grounds.
Issue:
- Whether the Deed of Partition with Sale and the Deed of Absolute Sale are authentic and valid.
- Whether petitioners substantiated their claim of ownership.
- Whether the failure to register the deeds with the Register of Deeds affected the validity of the transactions.
- Whether the notebook containing the memorandum of installment sale was a valid document of transfer.
- Whether Petra Bilog's title is indefeasible under the Torrens system.
Ruling:
The Supreme Court granted the petition, reversing the Court of Appeals' decision and reinstating the Regional Trial Court's ruling. The Court held that:
- The Deed of Partition with Sale and the Deed of Absolute Sale were valid and duly notarized public documents, enjoying the presumption of authenticity and due execution.
- Petra Bilog failed to specifically deny under oath the genuineness of the documents, thus admitting their validity.
- The failure to register the deeds did not invalidate the transactions, as registration is only for convenience and does not affect the validity of the contract.
- The memorandum of sale in the notebook was sufficient to prove the transaction between Fortunata Calonge-Agasen and Leonora Calonge.
- Petra Bilog's title was not indefeasible, as it could be attacked through an action for annulment or reconveyance.
Ratio:
- Presumption of Validity of Notarized Documents: Notarized documents are public documents presumed valid unless proven otherwise. Petra Bilog failed to overcome this presumption.
- Specific Denial Requirement: Under the Rules of Court, the genuineness and due execution of documents must be specifically denied under oath. Petra Bilog's failure to do so amounted to an admission of the documents' validity.
- Consensual Nature of Contracts: Contracts, including sales of land, are perfected by mere consent. Registration is not a requirement for validity but for convenience and protection of third parties.
- Indefeasibility of Title: The rule on indefeasibility of Torrens titles applies only to original titles, not subsequent registrations. Petra Bilog's title could be challenged through an action for annulment or reconveyance.
- Long Possession as Evidence of Ownership: Petitioners' long-standing possession of the land and the construction of a house thereon supported their claim of ownership.