G.R. No. 140752 - Caraan vs. Court of Appeals

Dionisio Caraan (represented by Heidi Caraan and Erlinda Caraan) is the petitioner in the case, while the respondents are spouses Salcedo R. Cosme and Nora Linda S. Cosme.
The dispute centers on the property located at No. 65 Commodore St., Veterans Subdivision, Barangay Holy Spirit, Quezon City, which is allegedly registered in the respondents’ name by Transfer Certificate of Title (TCT) No. 214949.

On September 16, 1992, the respondents filed an acción reivindicatoria (action for recovery of possession) in the Regional Trial Court (RTC) of Quezon City, Branch 104.
In their complaint, the respondents alleged that:

They are the registered owners of the subject property, as evidenced by TCT No. 214949 and its reconstituted form (TCT No. RT-71061).
They had paid realty taxes on the property from 1969 to 1993.
The petitioner unlawfully occupied the property since March 1991, constructing a residential house there without the respondents’ knowledge or consent.
Repeated oral and written demands to vacate the premises, culminating in a written demand on August 7, 1992, went unheeded.

The RTC conducted a trial on the merits and rendered a decision on August 9, 1995.
The decision ordered the petitioner to:

Vacate the premises and deliver possession to the respondents.
Pay the respondents P54,000.00 as reasonable compensation for the use and occupancy of the property.
Pay additional amounts for moral damages (initially P30,000.00) and attorney’s fees (P20,000.00), along with the costs of the suit.

The petitioner appealed the RTC decision to the Court of Appeals (CA).
On October 29, 1999, the CA affirmed the trial court’s ruling with modifications by:

Reiterating the unequivocal nature of the Torrens system whereby a certificate of title is conclusive evidence of ownership.
Deleting the sums ordered for moral damages, attorney’s fees, and part of the compensation.

Subsequent to the CA’s decision, the petitioner passed away, and his surviving heirs substituted as petitioners in the petition for review on certiorari.

They argued that the respondents’ TCT No. 214949 derived from documents (notably OCT No. 614 and TCT No. 3548) that were allegedly spurious or null and void.
They asserted that they had occupied the property in an open, adverse, continuous, and uninterrupted manner for over thirty years, claiming a right through acquisitive prescription.
They claimed that the subject property was part of a large tract of public land not yet classified for alienation.

They maintained that a certificate of title is conclusive and cannot be collateral attacked except in a separate direct proceeding for cancellation of title.
They presented the original reconstituted title (TCT No. RT-71061) in evidence, and any challenge to its validity is procedurally barred.

The respondents submitted a photocopy of the title as Exhibit A, which was stipulated to be a faithful reproduction of the original.
Petitioners failed to timely object to the method of presentation, thereby waiving any challenge concerning the admissibility of the evidence.

Whether the petitioners’ challenge to the respondents’ certificate of title—asserting it is derived from spurious and null documents—is a valid collateral attack.
Whether the petitioner’s claim of adverse, continuous, and uninterrupted possession for more than thirty years can overcome the conclusive effect of the Torrens system of title registration.
Whether the documentary evidence, specifically the photocopy of TCT No. RT-71061, was properly admitted into evidence notwithstanding petitioners’ later objections.
Whether the disputed property, being allegedly part of unclassified public forest land, may alter the determination of ownership through registration.