Facts:

The case of Mariano Angeles vs. Elena Samia revolves around a dispute over the ownership of a parcel of land measuring 7 hectares, 13 ares, and 81 centiares, located in Bacolor, Pampanga. The land in question is part of lot No. 3679, as described in cadastral record No. 11 of the municipality, and is covered by original certificate of title No. 8995, which was registered on December 15, 1921. This title was issued in the names of four co-owners: Macaria Angeles, Petra Angeles, Felisberto Samia, and Elena Samia, with respective shares of one-third, one-sixth, one-fourth, and one-fourth. The plaintiff, Mariano Angeles, claims to be the exclusive owner of the property, asserting that he inherited it from his father, Antonino Angeles, prior to 1896 and has possessed it continuously since then. The defendant, Elena Samia, contends that the property was allotted to her following a partition among the co-owners and argues that any rights the plaintiff had to the land have long sin...

Facts:

1. Ownership and Partition of the Land:

   • The case involves a parcel of land in Bacolor, Pampanga, with an area of 7 hectares, 13 ares, and 81 centiares, registered under Original Certificate of Title No. 8995 on December 15, 1921.
   • The land was registered in the names of Macaria Angeles, Petra Angeles, Felisberto Samia, and Elena Samia as co-owners in the following proportions: 1/3 to Macaria, 1/6 to Petra, 1/4 to Felisberto, and 1/4 to Elena.

2. Plaintiff’s Claim:

   • Mariano Angeles, the plaintiff, claims exclusive ownership of the land, asserting that he inherited it from his father, Antonino Angeles, before 1896.
   • He possessed and occupied the land openly and continuously until March 1933.
   • In 1909, he attempted to register the land under the Land Registration Act, but his application was denied due to errors in the plan.

3. Defendant’s Claim:

   • Elena Samia, the defendant, claims ownership based on a partition agreement among the co-owners, where the land was allotted to her.
   • She argues that the plaintiff’s right to the land, if any, had already prescribed.

4. Key Events:

   • The land was included in the cadastral survey and registered in the names of the co-owners without the plaintiff’s knowledge.
   • In 1933, the defendant attempted to exercise ownership by cutting nipa palms on the land, leading to a dispute.
   • The plaintiff requested the defendant to transfer the land to him, but she refused, claiming her title was indefeasible.

5. Lower Court Decision:

   • The lower court ruled in favor of the plaintiff, ordering the defendant to execute a deed of conveyance for the land and to pay the costs of the trial.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Prescription:

   • The defendant’s claim of prescription fails because she and her co-owners never possessed the land or exercised acts of ownership over it. The plaintiff’s continuous possession since before 1896 negates the defense of prescription.

2. Torrens System:

   • The Torrens System aims to confirm and register existing titles, not to create new ones. A certificate of title obtained through error or fraud does not confer indefeasible ownership.

3. Constructive Trust:

   • A constructive trust arises when property is registered in the name of someone who does not rightfully own it. The plaintiff’s rightful ownership of the land creates an implied trust in his favor.

4. Correction of Errors:

   • Errors in land registration, such as the inclusion of land in a certificate of title due to a mistake, can be corrected under Section 112 of Act No. 496. The plaintiff is entitled to the transfer of the land based on his proven ownership.

5. Applicability of Precedents:

   • The cases of Dizon vs. Datu, Government of the Philippine Islands vs. Court of First Instance of Nueva Ecija, and Palet vs. Tejedor support the plaintiff’s claim and the lower court’s decision.