Title
Blas vs. De la Cruz
Case
G.R. No. L-11284
Decision Date
Oct 13, 1917
Land registration under Torrens system includes all improvements unless excluded; failure to claim during proceedings forfeits rights, ensuring title finality.
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Case Digest (G.R. No. L-11284)

Facts:

  1. Background of the Case:

    • The case originated from a land registration dispute. Vicente de la Cruz filed a petition in the Court of Land Registration to register several parcels of land under the Torrens system.
    • Simeon Blas opposed the registration, claiming ownership of a portion of the land described in de la Cruz's petition.
  2. Proceedings in the Court of Land Registration:

    • The Court of Land Registration initially excluded the portion claimed by Blas from the lands to be registered in de la Cruz's name.
    • De la Cruz appealed the decision to the Supreme Court, which modified the lower court's ruling on March 16, 1915, and ordered the registration of the disputed portion in de la Cruz's name.
  3. Current Action:

    • Simeon Blas filed the present action seeking an injunction to prevent the defendants (Vicente de la Cruz and the sheriff) from destroying buildings and improvements on the disputed land.
    • The defendants demurred to the petition, and the lower court sustained the demurrer, dissolving the temporary injunction. Blas appealed to the Supreme Court.
  4. Key Question:

    • Whether the decree of registration under the Torrens system includes buildings and improvements on the land when they are not expressly excluded in the decree.

Issue:

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Ruling:

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Ratio:

  1. Finality of Torrens System:

    • The Torrens system aims to provide conclusive and incontrovertible titles to land, thereby preventing future litigation over ownership.
    • A decree of registration binds the land and all its appurtenances, including buildings and improvements, unless expressly excluded.
  2. Failure to Assert Claims During Registration:

    • A party opposing registration must assert all claims, including claims to improvements, during the registration proceedings.
    • Failure to do so results in the loss of such claims, as they are deemed included in the decree of registration.
  3. Exceptions Under Section 39 of Act No. 496:

    • The exceptions to the finality of a Torrens title (e.g., liens, claims, or rights arising under the laws of the Philippines) do not include unclaimed improvements.
    • Article 453 of the Civil Code, which protects possessors in good faith, does not apply when the claimant fails to raise the issue during registration proceedings.
  4. Policy Considerations:

    • Allowing separate claims to improvements after registration would defeat the purpose of the Torrens system, which is to ensure the quiet and peaceful enjoyment of land titles.


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