Facts:

• On September 4, 1997, spouses Conrado S. Reyes and Fe de Kastro Reyes (the Reyeses) filed for annulment of Original Certificate of Title (OCT) No. P-928 against spouses Crispin and Caridad Galang (the Galangs) in the Regional Trial Court (RTC) of Antipolo, Rizal, under Civil Case No. 97-4560.
• The Reyeses claimed ownership of two properties: Ponderosa Heights Subdivision and an adjoining property covered by Transfer Certificate of Title (TCT) No. 185252, totaling 1,201 square meters.
• They alleged that these properties were separated by Marigman Creek, which dried up in 1980 due to a natural change in its course.
• The Reyeses accused the Galangs of fraudulently obtaining a title over the dried creek bed, designated as Lot 5735, Cad 29 Ext., Case-1, with an area of 1,573 square meters, covered by OCT No. P-928.
• The Reyeses discovered this title in March 1997 through their caretaker, who had previously attempted to title the property in 1984 but faced financial issues.
• The Galangs denied the allegations, asserting legal acquisition of the title through compliance with Department of Environment and Natural Resources (DENR) requirements and long-term possession of the land.
• The RTC dismissed the Reyeses' complaint on July 16, 2004, citing insufficient evidence of actual fraud and stating that only the State could annul a title issued on public land.
• The Court of Appeals (CA) reversed this decision on April 9, 2008, ordering the cancellation of the Galangs' title and reconveyance of the land to the Reyeses.
• The Galangs' motion for reconsideration was denied on October 6, 2008, leading them to file a petition for review.

Issue:

• (Unlock)

Ruling:

• The Supreme Court ruled in favor of the Galangs, reversing the CA's decision.
• The Court held that while the Reyeses had the right to file an action for annulment of the title, they failed to prove their allegations of fr...(Unlock)

Ratio:

• The Court clarified that the Reyeses were not seeking reversion of the title, which would require State action, but rather an annulment based on their claim of prior ownership before the Galangs' title issuance.
• The distinction between annulment and reversion was emphasized, allowing private parties to assert ownership claims through annulment.
• The...continue reading