G.R. No. 140335 - Gaminde vs. Commission on Audit

The consolidated cases involve Spouses Yu Hwa Ping and Mary Gaw, heirs of Spouses Andres Diaz and Josefa Mia, and respondent Ayala Land, Inc. (ALI).
The dispute centers on the validity of certain Transfer Certificates of Title (TCTs) and Original Certificates of Title (OCTs) covering parcels of land in Las Piñas, Rizal.
Petitioners challenged the validity of ALI’s titles, asserting that they were based on void surveys and technical descriptions.
The contested titles originated from OCT Nos. 242, 244, and 1609, while petitioners’ titles derived from OCT No. 8510.

The Court of Appeals rendered a decision on February 8, 2005, affirming the invalidity of ALI’s titles based on defective surveys, which was reversed on June 19, 2006.
The Supreme Court, in a July 26, 2017 decision, reversed the Court of Appeals’ June 19, 2006 decision, reinstating the February 8, 2005 ruling.
ALI filed a first Motion for Reconsideration, which was denied on December 4, 2017.
ALI then filed a Second Motion for Reconsideration and a motion to elevate the case to the Court en banc, which are the subjects of the instant Resolution.

Petitioners’ titles are based on survey plan Psu-25909 dated March 17, 1921, approved by the Director of Lands, and originating from OCT No. 8510, issued on May 19, 1970.
ALI’s titles are based on survey plans Psu-47035 (1925), Psu-80886 (1930), and Psu-80886/SWO-20609 (1931), all prepared by the same surveyor, A.N. Feliciano, but containing numerous glaring irregularities and discrepancies.
The disputed surveys differ in location descriptions, signatures, and approval status, with questionable references to a monument (B.L.L.M No. 4) established only years after some surveys were done.
Verification surveys ordered by the Regional Trial Court (RTC) of Las Piñas revealed overlapping areas and technical anomalies in ALI’s title surveys.
The RTC ruled in favor of the petitioners, ascribing superior validity to their titles based on Psu-25909.

ALI argued that its titles cannot be declared void merely because surveys are alleged defective; that registration is conclusive and registration date governs priority.
ALI further claimed the issue was res judicata due to earlier rulings affirming their titles’ validity in other cases (Spouses Carpo v. ALI; Realty Sales v. IAC).
ALI also questioned the timeliness of the petitioners’ cause of action, claiming prescription barred the attack against their titles.

Whether the Supreme Court erred in invalidating Ayala Land, Inc.’s titles on the ground of defective and irregular surveys and technical descriptions.

Whether the general rule that in case of two titles involving the same land, the earlier certificate prevails, applies absolutely or whether exceptions apply.

Whether the Second Motion for Reconsideration and motion to elevate the case to the Court en banc should be granted.

Whether petitioners’ action is barred by prescription or res judicata based on prior decisions affirming ALI’s titles.

Whether ALI was an innocent purchaser for value entitled to protection under the Torrens system.