Facts:

On January 4, 1960, Elisa D. Gabriel, the petitioner and appellee, filed an adverse claim with the Register of Deeds of Manila against properties registered in the name of her sister, Juanita R. Domingo, the respondent and appellant. Gabriel asserted that despite the properties being registered under Domingo's name, they were part of the amended inventory of the estate of their deceased mother, Antonia Reyes Vda. de Domingo. Gabriel claimed that the properties were fraudulently registered in Domingo's name, depriving her of her rightful inheritance as an heir. On the same day, Gabriel also filed a similar adverse claim with the Register of Deeds of Rizal for properties located in Rizal Province, again asserting that these properties belonged to their late mother and were wrongfully registered in Domingo's name.

In response, Domingo opposed the adverse claim, alleging that it was intended to harass her and lacked legal basis, claiming that the properties were acq...

Facts:

Background of the Parties:
Elisa D. Gabriel (petitioner) and Juanita R. Domingo (oppositor) are sisters and heirs of the late Antonia Reyes Vda. de Domingo.

Petitioner’s Claim:
On January 4, 1960, Elisa D. Gabriel filed an adverse claim with the Register of Deeds of Manila and Rizal against properties registered in Juanita R. Domingo’s name. Gabriel alleged that the properties were acquired by their late mother, Antonia Reyes Vda. de Domingo, during her lifetime and should have been registered in her name. She claimed that Juanita fraudulently registered the properties in her own name, depriving Gabriel of her rightful share as an heir.

Oppositor’s Defense:
Juanita R. Domingo opposed the adverse claims, arguing that the claims were filed to harass her and had no legal basis. She also contended that the properties were acquired through an extrajudicial partition signed by Gabriel and their mother.

Action by the Registers of Deeds:

1. The Register of Deeds of Manila elevated the matter to the Land Registration Commission (LRC) for determination, expressing doubt about the propriety of the adverse claim.
2. The Register of Deeds of Rizal denied the registration of the adverse claim, stating it was legally defective and that other remedies under the law should have been pursued.

Appeal to the Land Registration Commission:
Gabriel appealed the denial by the Register of Deeds of Rizal to the LRC. The LRC held that the adverse claims were registrable, as they substantially complied with Section 110 of Act No. 496. However, the LRC clarified that registration does not equate to validity, which should be determined by a court of competent jurisdiction.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Registrability of Adverse Claims: An adverse claim is registrable if it complies with the requirements of Section 110 of Act No. 496, which includes a written statement detailing the claimant’s alleged right or interest, how it was acquired, and a reference to the certificate of title. The Register of Deeds does not have the authority to assess the validity of the claim but must ensure it meets the formal requirements.
2. Ministerial Duty of the Register of Deeds: The Register of Deeds’ role is ministerial, not judicial. They must register adverse claims that comply with the law, leaving the question of validity to a competent court. The court will determine whether the claim is frivolous, vexatious, or valid after a hearing.
3. Separation of Functions: The registration of an adverse claim does not create a right or lien but serves as notice of a dispute. The validity of the claim must be adjudicated by the court, not the Register of Deeds.