G.R. No. 93640 - Tay Chun Suy vs. Court of Appeals

Respondent Iluminada Cruz is the registered owner of a parcel of land under Transfer Certificates of Title (TCT) No. M-19968 and TCT No. 19973, both issued by the Registry of Deeds of Malabon City.
Portions of this land were occupied by petitioners Ricardo Santos and Paula Santos Wong, who claimed that parts of the property were sold to them.
Petitioners based their claim on a Deed of Absolute Sale dated August 28, 1978 (in favor of Ricardo Santos and his spouse) and a Subdivision Agreement with a Contract of Sale dated July 31, 1976 (allegedly executed in favor of Paula Wong and her deceased husband Marcos Santos).
In contrast, respondent Cruz relied on the authenticity and indefeasibility of her TCTs, which are conclusive and valid against any adverse claims.

Respondent Cruz initiated two actions for ejectment (Civil Case Nos. JL00-346 and JL00-347) alleging that petitioners occupied her property without consent and constructed structures without permission.
Petitioners, in their answer, admitted respondent’s title but insisted on their right to occupy portions of the land based on the alleged sale and subdivision agreements.
The Metropolitan Trial Court (MTC), Branch 55 of Malabon City, rendered a Joint Decision on February 4, 2005 dismissing respondent’s complaint for failing to prove its cause of action, also dismissing petitioners’ counterclaims for attorneys’ fees.
Dissatisfied with the MTC ruling, respondent Cruz appealed to the Regional Trial Court (RTC), Branch 170 of Malabon City, which reversed the MTC decision. The RTC ordered:

Eviction and demolition of the structures built by petitioners.
Payment of a monthly fee of Php20,000.00 from the date of the demand letter as compensation for the continued use of the premises until vacated.
Payment of Php30,000.00 as attorneys’ fees plus the costs of the suit.

Petitioners filed a petition for certiorari before the Supreme Court, alleging that the RTC’s decision violated their right to procedural and substantive due process.
Before the petition could be entertained, the Court issued a resolution on October 3, 2005, mandating the payment of additional fees and the submission of several certifications and proofs, including:

Petitioners later submitted a two-page petition on November 4, 2005, which was found to be deficient. It was written on an informal medium (old, torn paper) and failed to include the required certifications and documentation.

Petitioners’ evidence centered on photocopies of an alleged Deed of Absolute Sale and a Subdivision Agreement, aiming to assert their ownership over portions of the respondent’s property.
Respondent Cruz's evidence rested on the valid and conclusive TCTs (TCT No. M-19968 and TCT No. 19973), embodying the principle that a Torrens title is indefeasible and valid against the whole world.
The core dispute, therefore, involved whether an unregistered deed of sale and subdivision contract could ever defeat the registered certificate of title under the Torrens system.

Whether the petitioners’ petition for certiorari was in proper form and complied with mandatory procedural requirements.
Whether the petition demonstrated, with specific factual allegations, the violation of their right to due process by the lower court.

Whether petitioners should have first exhausted the ordinary remedy of filing a motion for reconsideration before directly invoking the certiorari remedy.
Whether the existence of an adequate appeal (or reconsideration) negated the need for a direct recourse to the Supreme Court through certiorari.

Whether petitioners’ reliance on photocopied unregistered documents (a deed of sale and a subdivision contract) is sufficient to challenge the conclusive nature of the respondent’s registered TCTs.
Whether the principle of indefeasibility under the Torrens system precludes the unregistered documents as valid evidence to override the certified titles.