Facts:

This case involves a legal dispute between Laura E. Paraguya (petitioner) and Spouses Alma Escurel-Crucillo and Emeterio Crucillo (respondents), as well as the Register of Deeds of Sorsogon. The conflict arose over certain parcels of land located in Maragadao, Villareal, Gubat, Sorsogon. The events date back to December 19, 1990, when Paraguya filed a complaint with the Regional Trial Court (RTC) of Gubat, Sorsogon, seeking to annul Original Certificate of Title (OCT) No. P-17729 issued to Escurel and requesting the cancellation of this title along with a related decree. Paraguya claimed that Escurel fraudulently obtained the title, even asserting that she rightfully inherited the land from her grandfather, Ildefonso Estabillo. Importantly, Escurel had acted merely as an administrator of the estate and thus had no legitimate claim over the property.

In response, on January 18, 1991, the Register of Deeds filed an answer, maintaining that its issuance of the title was merely min

...

Facts:

Background of the Case

• On December 19, 1990, petitioner Laura E. Paraguya filed a complaint before the Regional Trial Court (RTC) of Gubat, Sorsogon, seeking the annulment of Original Certificate of Title (OCT) No. P-17729 and other related deeds, along with a prayer for receivership and damages.
• Paraguya alleges that the title was obtained through fraud and deceit by Escurel, who she claims acted merely as the administrator of the properties, while Paraguya herself is the lawful heir to the estate of her paternal grandfather, the late Ildefonso Estabillo.

Parties Involved and Alleged Claims

• Petitioner: Laura E. Paraguya – asserting her rightful claim to the subject properties based on her family lineage.
• Respondents:
• Spouses Alma Escurel-Crucillo and Emeterio Crucillo – alleged to be in wrongful possession of the subject properties.
• The Register of Deeds (RD) of Sorsogon – maintained that issuance of OCT No. P-17729 was merely a ministerial duty.
• Additional Background:
• Prior to the complaint, there existed a stipulation among the parties confirming:
• The identity of the subject properties covered by the said title.

ii. The common ancestral connection whereby the properties originally belonged to Estabillo, the ancestor of both Paraguya and Escurel. iii. That the Crucillos were in actual possession of the said properties.

Pre-Trial and Trial Proceedings

• Pre-Trial Developments:
• Answers were filed by the RD and later by the spouses Crucillo, the latter also moving to dismiss based on laches and prescription.
• Allegations were made that Escurel, through her father (the late Angel Escurel), had applied for a free patent over the subject properties, resulting in the issuance of Free Patent No. V-3005844 under OCT No. P-17729 in her name.
• Trial Evidences and Testimonies:
• Paraguya presented documents including a Recognition of Ownership and Possession (dated December 1, 1972) and a titulo posesorio reportedly issued in 1893 or 1895 in the name of Estabillo.
• A representative from the Community Environment and Natural Resources Office (CENRO) testified on Paraguya’s behalf, highlighting an affidavit dated December 17, 1976, executed by Adonis Escurel (Escurel’s brother).
• The Crucillos, on their part, cited testimonies establishing that Escurel had possessed the subject properties as an owner since 1957 and admitted to submitting relevant affidavits supporting her free patent application.

RTC Ruling

• On April 22, 2009, the RTC ruled in favor of Paraguya, ordering the annulment of OCT No. P-17729.
• The basis for the decision included:
• A significant discrepancy in the land area as evidenced by Adonis Escurel’s affidavit (stating 8,392 square meters) versus the OCT (stating 30,862 square meters).
• A finding that Escurel’s ownership was unproven and her affidavit of adjudication was self-serving, thus establishing fraud in her acquisition of the title.
• Subsequent Developments:
• A motion for reconsideration, filed by the heirs of the late spouses Crucillo, was denied on December 16, 2009.
• The case was then elevated to the Court of Appeals (CA).

CA Proceedings and Resolute Developments

• On June 27, 2011, the CA reversed the RTC’s ruling and dismissed Paraguya’s complaint.
• The CA’s rationale included:
• Application of Section 32 of Presidential Decree (PD) No. 1529, which holds that a Torrens title becomes incontrovertible and indefeasible one year after its issuance.
• Noting that the OCT, issued on August 24, 1979, was well beyond the one-year period by the time of the complaint filed in 1990.
• The express trust relationship between Escurel and Estabillo was not sufficiently established.
• Paraguya was deemed not to have a real party in interest since her titulo posesorio could no longer serve as evidence of ownership.
• A subsequent motion for reconsideration filed by Paraguya on January 9, 2012, was denied, leading to the petition for review on certiorari.

Issue:

Whether the Court of Appeals correctly dismissed Paraguya’s complaint for annulment of title.

• Is the application of Section 32 of PD 1529, which bars contesting the title after one year from its issuance, appropriately invoked?
• Whether the evidence presented, particularly the titulo posesorio and affidavits, suffices to overcome the prescriptive period and the doctrine of indefeasibility under the Torrens system.
• Whether Paraguya, as a real party in interest, properly substantiated her claim to the subject properties given the lapse of time and statutory limitations.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)