Facts:

The case revolves around the dispute between Rosario Banguis-Tambuyat (petitioner) and Wenifreda Balcom-Tambuyat (respondent) related to the ownership of a parcel of land located in Barangay Muzon, San Jose del Monte, Bulacan. Adriano M. Tambuyat (Adriano) and Wenifreda were married on September 16, 1965, and during their marriage, Adriano acquired several properties, including the subject property which was purchased on November 17, 1991. The deed of sale for the property was signed by Adriano alone, while Banguis acted only as a witness. However, the Transfer Certificate of Title No. T-145321(M), issued later, incorrectly listed the property in the name of "Adriano M. Tambuyat married to Rosario E. Banguis."

It is critical to note that at all times, Rosario Banguis was still legally married to Eduardo Nolasco, as their marriage which occurred on October 15, 1975, had not been annulled or dissolved. Adriano passed away intestate on June 7, 1998. Subsequently, Wenifred

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Facts:

Background of the Parties and Property Acquisition

• Adriano M. Tambuyat and Wenifreda Balcom-Tambuyat were legally married on September 16, 1965.
• During their marriage, Adriano acquired several real properties, notably a 700‑square meter parcel located at Barangay Muzon, San Jose del Monte, Bulacan (the subject property).
• The subject property was bought on November 17, 1991, evidenced by a deed of sale executed in Manila in which Adriano appears as the sole purchaser.
• Rosario Banguis-Tambuyat, the petitioner, signed as a witness on the deed of sale, although her capacity in the transaction later became a central point of controversy.

Issues with the Title and Subsequent Registrations

• When the Transfer Certificate of Title (TCT No. T-145321 (M)) was issued, it was made in the name “ADRIANO M. TAMBUYAT married to ROSARIO E. BANGUIS.”
• It was later revealed that petitioner Banguis was, in fact, still married to Eduardo Nolasco, having wed him on October 15, 1975, which meant her alleged inclusion as Adriano’s spouse was erroneous.
• Adriano died intestate on June 7, 1998, which later led to Wenifreda filing a Petition for Cancellation of TCT T-145321 on October 18, 1999, asserting that:
• She was the surviving spouse of Adriano.
• The title was mistakenly registered in the name “Adriano M. Tambuyat married to Rosario E. BANGUIS” due to an insidious machination.
• Banguis’s continued claim would cause her damages, for which Wenifreda sought moral and exemplary damages, attorney’s fees, and costs.

Proceedings in the Lower Courts

• In the Regional Trial Court (Malolos RTC, Branch 10), LRC Case No. P-443-99 was filed by Wenifreda calling for the cancellation of the title and issuance of a new title in Adriano’s name with her as the spouse.
• The trial court ruled in favor of Wenifreda by canceling TCT T-145321, ordering the issuance of a new title (TCT T-433713 (M)), and awarding moral, exemplary damages, and attorney’s fees against Banguis.
• Banguis, in her Opposition, contended that:
• The subject property was acquired solely by her using personal funds.
• There existed a separate marital relationship between her and Adriano (claimed to have been married on September 2, 1988) and that they even produced a child.
• Jurisdiction issues were raised; she argued that the case addressed questions of ownership that required adjudication in a court of general jurisdiction rather than one limited to land registration matters.

Evidence Presented

• Documentary evidence regarding marital contracts of both Adriano with Wenifreda and of Banguis with Nolasco, including corresponding Social Security and Barangay Council Certificates.
• The deed of sale and its corresponding entry indicating Adriano as the sole vendee of the subject property.
• Testimonies from Banguis on direct examination and during cross-examination confirming her subsisting marriage with Nolasco and the absence of any legal marriage between herself and Adriano.
• Other evidences such as photographs, correspondence, a negative certification of marriage in the case of the alleged marriage with Adriano, and testimony regarding the execution of the deed in question.

Procedural Developments

• The trial court issued a decision on May 26, 2003, affirming the cancellation of TCT T-145321 under Section 108 of PD 1529 and ordering a reissuance in favor of Adriano’s true surviving spouse – Wenifreda.
• Subsequently, the Court of Appeals (CA) in its decision dated February 14, 2012, affirmed the trial court’s decision with the modification that the award of damages, attorney’s fees, and costs be deleted.
• Banguis’s counterclaim and arguments regarding jurisdiction and ownership were rejected, with the CA emphasizing that the corrections under Section 108 were summary in nature and that her evidence did not substantiate her claim as co-owner.

Issue:

Jurisdiction and Proper Forum for Review

• Whether the trial court, acting as a land registration court, had jurisdiction to rule on the petition for cancellation involving questions of marital relationships and property ownership.
• Whether the separate and controversial issues regarding Banguis’s claimed ownership (and the alleged need for estate proceedings) required a different proceeding in a court of general jurisdiction.

Application of Section 108 of PD 1529

• Whether Section 108 of the Property Registration Decree correctly applies to correct or amend the title despite the contested issues raised by Banguis.
• Whether the error in the registration of the title (naming Banguis as Adriano’s spouse instead of Wenifreda) warranted solely a clerical correction or if it involved substantive issues that needed to be determined in a separate action.

Evidence of Ownership and Proof of Marriage

• Whether the documentary and testimonial evidence conclusively established Wenifreda as the legitimate surviving spouse of Adriano.
• Whether Banguis’s evidence, including her claim of sole purchase of the property and the existence of an alleged marriage with Adriano, sufficed to establish her as a co-owner or as Adriano’s spouse in contrast to Wenifreda.

Appropriateness of Awarding Damages and Granting Execution

• Whether the trial court erred in awarding moral and exemplary damages, along with attorney’s fees, given that the petition was aimed at correcting a clerical error rather than settling ownership disputes.
• The propriety of granting execution pending appeal without any special reasons and despite Banguis’s contentions.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)