Title
Bank of the Philippine Islands vs. Acuna
Case
G.R. No. 36890
Decision Date
Dec 21, 1933
Dispute over 1,600-hectare land in Rizal; defendants occupied without title; Torrens title upheld, no compensation for bad-faith improvements.
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Case Digest (G.R. No. 36890)

Facts:

  1. Parties Involved:

    • Plaintiff and Appellee: Bank of the Philippine Islands (as receiver of the Tuason Entail).
    • Defendants and Appellants: Pascual Acuna and others (divided into two groups: the Bagobantay group and the Diliman group).
  2. Subject Matter:

    • The case involves a dispute over land within the Santa Mesa and Diliman hacienda, located in the barrios of Bagobantay and Diliman, municipalities of Caloocan and San Juan del Monte, Province of Rizal.
  3. Ownership and Title:

    • The Tuason Entail holds a Torrens title (Certificate of Title No. 3792) to the land, which covers approximately 1,600 hectares. The title was issued in lieu of an older certificate dated July 8, 1914.
  4. Defendants' Occupation:

    • In October 1929, the defendants entered and occupied portions of the land without any legal right or title.
  5. Claims and Counterclaims:

    • The plaintiff sought to recover possession of the land, declare that the defendants had no dominical rights, and recover damages.
    • The defendants, in their answer, denied the claims and filed cross-complaints, seeking compensation for improvements they allegedly made on the land.
  6. Trial Court Decision:

    • The Court of First Instance of Rizal ruled in favor of the plaintiff, declaring that none of the defendants owned any part of the land and ordering them to surrender possession. The court also disallowed the defendants' counterclaims for improvements.
  7. Appeal:

    • Two groups of defendants (Bagobantay and Diliman) appealed the decision.

Issue:

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Ruling:

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Ratio:

  1. Imprescriptibility of Torrens Title:

    • Under Section 46 of Act No. 496 (Land Registration Act), rights acquired under a Torrens title are imprescriptible. The defendants, having no legal title or right, cannot claim ownership or compensation based on their occupation.
  2. Bad Faith Occupation:

    • The defendants' occupation of the land was in bad faith, as they had no color of title or legal justification. Improvements made in bad faith do not entitle the possessor to compensation.
  3. Validity of Torrens Title:

    • The Torrens title held by the plaintiff is valid. The procedural argument raised by the defendants regarding the amendment of the survey plan during registration is irrelevant, as the amendment involved the exclusion of land, not the inclusion of additional land.
  4. No Legal Basis for Counterclaims:

    • The defendants' counterclaims for improvements were properly disallowed, as they lacked any legal basis. The trial court's findings, supported by the assessors' report, confirmed that the alleged improvements were either nonexistent or made in bad faith.


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