G.R. No. 233304 - Republic vs. Tongson, Sr.

J.M. Tuason & Co., Inc. (petitioner) initiated an ejectment action to recover possession of a disputed parcel of land in Quezon City.
The petitioner is the registered owner of the land as evidenced by Torrens Title (T.C.T. No. 1267).
Private respondent Guillermo Renosa built his residence on a 100-square-meter portion of the property on February 6, 1967.
The reasonable rental value of the portion occupied by Renosa was determined to be P12 per month.

The case originated as an action for recovery of possession (ejectment) filed in the Court of First Instance of Rizal, Quezon City, Branch V.
The trial court ruled in favor of the petitioner, ordering respondent Renosa to remove his construction and pay rentals.
The Court of Appeals reversed the trial court’s decision, basing its judgment on the purported validity of a compromise agreement affecting the title.
The petitioner sought certiorari to review the decision of the Court of Appeals, and the case ultimately reached the Supreme Court.

The petitioner argued that it is the registered and rightful owner of the disputed land.
As owner, the petitioner is entitled to possession, and its Torrens title is conclusive and undefeatable.
The claim that respondent Renosa had any right to occupy the land based on a purchase from Capt. Faustino C. Cruz was legally unfounded.

Renosa defended his possession by asserting that he purchased the disputed 360 square meters for P3,600 from Capt. Faustino C. Cruz.
Renosa maintained that Capt. Cruz acquired a right to the property by virtue of a compromise agreement executed in April 1953.
The respondent claimed that the said compromise agreement conferred a beneficial right, capable of being transmitted to him as buyer.

The compromise agreement (Exhibit 1) was executed on April 10, 1953, between the petitioner and the “Deudors.”
Under the agreement, the petitioner reserved a total of 12,000 square meters for various persons, including Capt. Cruz, with a specific allotment of 3,000 square meters for him.
Crucially, the beneficial rights under the agreement were subject to suspensive conditions:

Payment of P250,000 by the “Deudors.”
Delivery of “refund” lots and approval of the subdivision plan by the National Housing Commission and the Bureau of Lands.

It was held that these suspensive conditions were never fulfilled, and therefore, the alleged beneficial rights never materialized into an effective title or possessory right.

The trial court found that respondent Renosa, as well as his predecessor-in-interest Capt. Cruz, never had a registered title to the disputed land.
Renosa admitted that the petitioner is the holder of the unassailable Torrens title, further weakening his claim of a better right of possession.
The deed of sale (Exhibit 2) from Capt. Cruz to Renosa claimed that Capt. Cruz was “the true and sole owner” by virtue of the amicable settlement obtained under the compromise agreement; however, this claim was not substantiated by registered title.

The decision references earlier cases, such as J.M. Tuason & Co., Inc. vs. Ponciano Hernandez and J.M. Tuason & Inc. vs. Rubillo San Diego, which repudiated Renosa’s claim based on the same compromise agreement.
The Supreme Court reaffirmed the principle that the registered Torrens title cannot be defeated by an unregistered equitable claim arising out of a compromise agreement subject to unmet conditions.

Whether Capt. Faustino C. Cruz, as a beneficiary under the compromise agreement, acquired a valid right to own and possess the disputed land.
Whether the suspensive conditions attached to the agreement were fulfilled, thereby giving rise to any enforceable title or possessory right.

Whether the rights, if any, of Capt. Cruz could be legally transferred to Renosa through the deed of sale executed in 1956.
Whether Renosa could claim a right to possession superior to that of the registered owner given the circumstances surrounding the compromise agreement.

Whether the unassailable Torrens title held by the petitioner overrides any claim arising from an unfulfilled agreement.
Whether mere possession or a claim of equitable interest can defeat the imprescriptible right of the registered owner.