G.R. No. L-43389 - Uy vs. Workmen's Compensation Commission

Respondent Doloreich Dumaluan filed a Complaint for Declaration of Nullity of Transfer Certificate Title (TCT) No. 29414 and Reconveyance with prayer for Injunctive Relief on June 6, 2005, before the Regional Trial Court (RTC) of Tagbilaran City, Bohol, Branch 2.
Doloreich claims ownership of a parcel of land covered by Tax Declaration (TD) No. TM3-838 over Lot No. 5682 with an area of 23,971 square meters, purchased from the heirs of the late Juan Dumaluan.

Original Certificate of Title (OCT) No. 75904, issued to Doloreich on May 29, 1996, only covers 16,298 square meters, less than the area stated in the tax declaration.
Doloreich discovered a sale on January 31, 1983, by Geralda, Leonardo, and Sotero Lorejo (the Lorejos) to Paulino Franco of a lot of 8,998 square meters, part of Lot No. 5682 covered by TD No. 33-03-0281.
Doloreich alleges this sale is void, asserting: (a) TD No. 33-03-0281 covers only 2,805 sq.m., and (b) Lorejos were not the owners and thus lacked authority to sell.

Franco subdivided Lot No. 5682 into 5682-A and 5682-B; Lot No. 5682-B is subject to pending litigation.
Franco consolidated 5682-A with other properties and obtained OCT No. 56607 on December 16, 1986.
The lot further subdivided into Lots 3-A, 3-B, and 3-C.
On July 29, 1993, Franco sold Lot 3-B to spouses Tirso and Ma. Perlita Uytengsu who were issued TCT No. 20887.
In 2002, the Uytengsu spouses sold Lot 3-B to petitioner Bohol Resort Development, Inc. (BRDI), which was issued TCT No. 29414 on February 28, 2003.

Doloreich insists Lot 3-B belongs to him and prays for nullity of BRDI's TCT and reconveyance, alleging extrinsic fraud by Franco in merging Lot 5682-A with other properties.
BRDI claims it is the registered owner, purchased Lot 3-B from spouses Uytengsu who bought it from Franco.
BRDI asserts the Lorejos owned undivided shares of the land sold to Franco as heirs of Valentin Dumaluan.
BRDI also contends discrepancies in the tax declarations were due to cadastral survey updates and claims Doloreich acted in bad faith.

On October 20, 2015, RTC dismissed the complaint for lack of cause of action, ruling BRDI was an innocent purchaser for value relying on the Torrens title.
Motion for reconsideration led to the RTC affirming dismissal but modifying the ground to prescription (statute of limitations), holding that Doloreich's action prescribed since 1986 registration of title by Franco.

On May 26, 2021, the Court of Appeals (CA) reversed and set aside the RTC dismissal, remanding the case for trial and resolution of injunctive relief.
The CA ruled that the issue of prescription could not be resolved without trial on the merits due to factual disputes about ownership and authority of the Lorejos to sell.
The CA emphasized that whether BRDI is an innocent purchaser for value is a factual issue requiring trial.

BRDI petitioned for certiorari, arguing that the CA erred in requiring a full-blown trial and in denying immediate dismissal based on prescription and innocent purchaser defense.

Whether the Court of Appeals correctly remanded the case to the Regional Trial Court for trial on the merits without resolving the question of prescription.
Whether the sole evidence submitted during preliminary hearings is sufficient to resolve the case without trial.
Whether the defense of being an innocent purchaser for value can be resolved prior to trial to dismiss the case.