Title
Cabangcala vs. Domingo
Case
G.R. No. L-7189
Decision Date
Oct 30, 1954
Alejandra Darang's heirs contested Severo Domingo's claim to her land, alleging invalid sale and transfer. Supreme Court ruled land registration court lacked jurisdiction, annulled transfer, and reinstated original title.
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Case Digest (G.R. No. L-7189)

Facts:

1. Ownership and Death of Alejandra Darang:
Alejandra Darang was the registered owner of Lot No. 842 in Rosales, Pangasinan, as evidenced by Original Certificate of Title No. 31699. She died intestate in 1935, leaving behind her husband, Pedro Cabangcala, and five minor children.

2. Severo Domingo's Claim:
Two years after Alejandra's death, Severo Domingo filed a petition in the cadastral case (G.L.R.O. Rec. No. 706), claiming that Alejandra had sold the lot to him for P500 during her lifetime. However, her sudden death prevented her from executing the necessary deed for registration. Domingo sought the cancellation of the original certificate of title and the issuance of a transfer certificate in his and his wife's name.

3. Court Proceedings and Transfer of Title:
The court set the petition for hearing and published a notice. No one contested the petition, and the court granted Domingo's request based on his evidence. The Register of Deeds implemented the order, transferring the title to Domingo.

4. Plaintiffs' Action for Annulment:
Ten years later, on April 8, 1949, Alejandra's children filed an action in the Court of First Instance of Pangasinan, seeking the annulment of the court order and the reinstatement of the original certificate of title. They argued that the court lacked jurisdiction to adjudicate the matter as a land registration court and that the issue should have been resolved in an ordinary civil action. They also sought damages for Domingo's occupation of the land since 1939.

5. Defendant's Defense:
Domingo maintained the validity of the sale and the transfer proceedings. He also pleaded prescription, arguing that the plaintiffs' right to question the sale had expired.

6. Lower Court's Decision:
The trial court upheld the sale and the transfer proceedings, dismissing the plaintiffs' complaint. The plaintiffs appealed to the Court of Appeals, which certified the case to the Supreme Court due to the legal questions and jurisdictional issues involved.

Issue:

  1. Jurisdiction of the Court:
    Did the Court of First Instance, acting as a land registration court, have jurisdiction to adjudicate the issue of the alleged sale and order the transfer of title?

  2. Validity of the Sale and Transfer Proceedings:
    Were the sale and the subsequent transfer of title valid, considering the lack of a formal deed of conveyance and the failure to notify the heirs?

  3. Prescription:
    Had the plaintiffs' right to question the sale prescribed?

Ruling:

The Supreme Court reversed the lower court's decision and annulled the proceedings and orders related to the transfer of title. The Court ordered the Register of Deeds of Pangasinan to cancel the transfer certificate of title issued to Domingo and reinstate the original certificate of title in Alejandra Darang's name. Costs were imposed on Domingo.

Ratio:

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