G.R. No. L-5367 - People vs. Cayetano Mangahas and Mariano de los Santos Mangahas

The dispute involves a parcel of land known as Lot 824-A-4, covered by Transfer Certificate of Title (TCT) No. RT-28758 (30627) PR-9639, located in Brgy. Matandang Balara, Quezon City, with an approximate area of 30,000 square meters.
The subject property is part of Lot 824 of the larger Piedad Estate, which spans 147,072 square meters and was originally registered in the name of Felipe Yu Han Yat.
Yu Han Yat subdivided the property into 60 lots under Subdivision Plan Psd-13-018013, leading to the issuance of derivative titles (TCT Nos. 47294 to 47353) after the cancellation of the original title.

To finance development of the property, Yu Han Yat secured loans from various banks using some of his TCTs as collateral.
When the mortgage instruments were presented for registration, a conflict arose because the Register of Deeds of Quezon City noted an overlap with boundaries covered by another title (TCT No. 336663) registered in the name of Esperanza Nava.
The Land Registration Authority (LRA), in Consulta No. 2038, reversed the Register’s refusal and ordered the registration of the mortgage instruments on Yu Han Yat’s titles.

Petitioners, namely Jose A. Bernas (for Wharton Resources Group (Philippines), Inc.) and Felomena S. Mejia, claimed ownership over the subject property.
Their claim is based on the assertion that Esperanza Nava was the registered owner of the land covered by TCT No. 336663 and that Nava sold parts of the property to Mejia and other parties.
Mejia executed a Deed of Sale with Right of Redemption with Nava on September 15, 1986, and upon Nava’s failure to redeem, Mejia consolidated title in her favor per a Regional Trial Court (RTC) decision dated June 28, 1990.

On February 21, 1992, Bernas, on behalf of Wharton, entered into a Memorandum of Agreement with Mejia, leading to a subsequent Deed of Sale conveying the subject property.
In April 1992, Bernas discovered that another title (TCT No. 30627) covering about three hectares overlapped a portion of the property recorded under TCT No. 336663.
Bernas filed an Affidavit of Adverse Claim on Yu Han Yat’s TCTs on June 24, 1992, asserting that a Deed of Sale executed between himself (for Wharton) and Mejia pertained to the overlapping area.

Following the refusal of the Register of Deeds to record the aforementioned mortgage instruments, Yu Han Yat filed a Petition for Quieting of Title before the RTC (Civil Case No. Q-92-13609) against multiple parties including the Estate of Nava, Galarosa, Mejia, Bernas, and the Register of Deeds.
Mejia and Bernas subsequently answered and interposed various defenses, including allegations of being innocent purchasers and contesting the validity of the title derived from Dominga Sumulong’s records.
The RTC issued orders, including a preliminary injunction in favor of Bernas, and trial proceedings unfolded with detailed documentary evidence tracing the chain of title from old certificates to the disputed titles.
The Court of Appeals (CA) later ruled in favor of Yu Han Yat, holding that his title (TCT No. 30627) was superior because it was issued earlier than the petitioners’ title (TCT No. 336663) and that any alleged typographical errors in annotations did not affect the substantial issue of which title persisted.

Petitioners contended that discrepancies in technical descriptions and annotations (notably the reference to “TCT No. 3633/T-R”) should invalidate Yu Han Yat’s claim over the subject property, arguing that the titles covered different parcels of land.
The CA, however, attributed the discrepancy to a typographical error, noting that both titles ultimately referred to Lot 824 of the Piedad Estate, now located in Quezon City.
Additional controversies involved the proper application of the Torrens system, the principle against collateral attacks (i.e., challenging title in a direct proceeding) and whether real property tax payments could confer evidence of ownership.

The CA awarded Yu Han Yat actual, moral, exemplary damages, and attorney’s fees on the ground that petitioners’ actions caused him financial loss and impeded his rights over the property.
In reviewing these awards, subsequent appellate proceedings questioned the propriety of such damages in the absence of malice or bad faith.

Whether petitioners complied with Rule 45 of the 1997 Rules of Civil Procedure in filing their Petitions dated April 15, 2011, and April 20, 2011.
Whether the separate filings by Bernas and Mejia constituted forum shopping and if the Petitions should be barred by res judicata.

Whether Yu Han Yat’s Petition for Quieting of Title constituted a collateral or a direct attack on the validity of the petitioners’ title (TCT No. 336663).
The importance of the nomenclature versus the substance of the relief being sought.

Whether the CA ruling that the property covered by Yu Han Yat’s title (TCT No. 30627) is the same as that covered by petitioners’ title (TCT No. 336663) is supported by the evidence on record.
Whether the chronological order of title issuances (with the earlier title prevailing under the Torrens system) was correctly established.

Whether the case of Manotok, et al. v. Barque is applicable in assessing the validity of the titles, particularly concerning the traceability of title back to valid alienation under Act No. 1120 (the Friar Lands Act).
Whether the CA erred in taking judicial notice of proceedings in other cases (for instance, CA-G.R. No. 77666) without proper notice or consent.

Whether Yu Han Yat’s alleged payment of real property tax constitutes proof of ownership or a superior title over the subject property.

Whether petitioners are liable for the damages and attorney’s fees awarded to Yu Han Yat, given the absence of malice in their actions and the principle of non-penalization for litigating in good faith.