Title
Heirs of Panganiban vs. Dayrit
Case
G.R. No. 151235
Decision Date
Jul 28, 2005
The Supreme Court determined the petitioners are the rightful owners of the property but cannot reclaim possession due to laches.
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Case Digest (G.R. No. 151235)

Facts:

  • The case involves the petitioners, the Heirs of Juan Panganiban and Ines Panganiban, including Erlinda B. Pacursa and others, against respondent Angelina N. Dayrit.
  • The petition was filed on April 3, 1992, seeking cancellation of the owner's duplicate copy of Original Certificate of Title (OCT) No. 7864 and recovery of damages.
  • The property in question is a 2,025-square meter portion of Lot 1436 in Kauswagan, Cagayan de Oro City, part of three lots covered by OCT No. 7864, registered to Juan and Ines Panganiban on April 17, 1940.
  • Juan passed away in June 1942, followed by Ines in April 1944. The petitioners claimed ownership of Lot 1436, inherited from Juan and Ines, acknowledging the sale of the other two lots in 1949.
  • The owner's duplicate of OCT No. 7864 was lost, but Erlinda successfully petitioned for its reissuance in 1977.
  • Cristobal Salcedo claimed ownership of Lot 1436 and sold a portion to the respondent, who later filed for a new owner's duplicate certificate, claiming the previous one was lost in a fire in 1981.
  • The new duplicate was issued to the respondent, including an annotation of Erlinda's Notice of Adverse Claim.
  • The petitioners contended that the new duplicate prejudiced their title, while the respondent claimed the petitioners sold the property in 1947.
  • The trial court ruled in favor of the respondent, but the Court of Appeals modified the ruling, affirming ownership while declaring the petitioners' duplicate certificate as valid.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court ruled that the petitioners are the rightful owners of Lot 1436, as the duplicate certificate of title in their possession is valid and subsisting.
  • The Court affirmed that t...(Unlock)

Ratio:

  • The Supreme Court emphasized that ownership of registered land is determined by the certificate of title, which serves as conclusive evidence of ownership.
  • The original owner's duplicate certificate of title was still in existence and in Erlinda's possession, meaning the trial court lacked jurisdiction to grant the respondent's petition for reconstitution.
  • The duplicate certificate issued to the respondent was deemed void.
  • Under Section 46 of the Land Registration Act, no title to registered land can be acquired through prescription or adverse possession against the ...continue reading

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