Case Digest (G.R. No. L-19118)
Facts:
Fil-Estate Management Inc., Megatop Realty Development, Inc., Peaksun Enterprises and Export Corp., Arturo Dy, and Elena Dy Jao v. George H. Trono et al., G.R. No. 130871, February 17, 2006, Supreme Court Second Division, Sandoval‑Gutierrez, J., writing for the Court. The petition was filed under Rule 45 of the Rules of Court.Respondents George H. Trono and his co‑heirs filed on November 9, 1994 an application for original registration of a 245,536‑square‑meter parcel in Bo. Almanza, Las Piñas City, docketed as LRC Case No. M‑228 before the Regional Trial Court (RTC), Branch 255. The Land Registration Authority (LRA) issued a Notice of Initial Hearing noting overlaps with several surveyed lots. During the proceedings the LRA and the DENR Land Management Services reported that the parcel applied for under Plan Psu‑31086 overlapped property already registered in petitioners’ names.
On August 11, 1995 petitioners filed an opposition to LRC M‑228 asserting their title (TCT No. T‑9182) had been registered in their names on April 28, 1989; Ayala Land, Inc. likewise opposed, asserting overlap with parcels covered by several TCTs. Petitioners and Ayala moved to dismiss the registration application for lack of jurisdiction, arguing that because the property was previously Torrens‑registered the RTC lacked jurisdiction to act.
On March 4, 1996 the RTC denied the motions to dismiss, ruling that the Court of First Instance (now RTC) has exclusive original jurisdiction over original registration and related petitions. Petitioners sought certiorari relief before the Court of Appeals (CA). On May 20, 1997 the CA granted the petition, holding that the incontrovertibility of title prevents a land registration court from acquiring jurisdiction over land already decreed and registered under the Torrens System, and ordered LRC M‑228 dismissed without prejudice. Petitioners filed a motion for partial reconsideration to have the dismissal made with prejudice and to declare respondents’ reconveyance actions prescribed.
Meanwhile, Ayala and respondents executed a compromise agreement (July 9, 1997); the CA issued an amendatory decision concluding the controversy between Ayala and respondents was moot, and on September 5, 1997 denied petiti...(Subscriber-Only)
Issues:
- Did the Regional Trial Court have jurisdiction to entertain respondents’ application for original registration of land (LRC Case No. M‑228) despite the existence of previously issued Torrens titles to petitioners?
- Should LRC Case No. M‑228 have been dismissed with prejudice and are respondents’ remedies for reconveyance or annulment of petitioners’ title already prescribed?
- Did respondents’ application for registration constitute an impermissible collat...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)