G.R. No. 86787 - Bishop vs. Court of Appeals

Case Summary (G.R. No. 86787)

Facts and Procedural History

The land in dispute is registered under Transfer Certificate of Title No. T-29018 in the name of the private respondents, Manuel and Jesusa Salang. On January 22, 1985, the respondents sued the petitioners for recovery of possession, invoking their rights as registered owners. The petitioners, in possession of portions of the land, contended that the lots were part of the public domain and, thus, could not have been validly registered under the Torrens system. They also alleged acquisition of their respective lots through long possession, citing tax declarations and, in some instances, valid contracts of sale or inheritance.

Findings of the Regional Trial Court

Judge Nicias O. Mendoza ruled in favor of the private respondents, finding that:

The plaintiffs, as registered owners in fee simple, have the lawful right to possess the land and to recover it from unlawful occupants under Article 428 of the New Civil Code.
The petitioners’ certifications from the Bureau of Forestry alleging the land as alienable and disposable public land lacked legal basis and deserved minimal consideration. Once registered, the land ceased to be public domain and became private property.
Tax declarations in the petitioners’ names do not constitute evidence of ownership where a Torrens title exists.
Possession by petitioners, despite its duration, could not ripen into ownership under acquisitive prescription because the land was covered by a Torrens title (Article 496).
Consequently, the court held that the petitioners’ occupation was unlawful and they were obliged to restore possession to the registered owners.

Ruling of the Court of Appeals and Petitioners’ Appeal

The Court of Appeals affirmed the trial court’s decision on August 22, 1988, and denied the petitioners’ motion for reconsideration. Petitioners then elevated the case to the Supreme Court, raising three main contentions:

The land is part of the public domain and improperly registered under the Torrens system.
The petitioners acquired ownership by laches through long possession.
Alternatively, the petitioners are builders in good faith entitled to protective rights under Articles 448, 546, 547, and 548 of the Civil Code.

Supreme Court’s Analysis of the Public Domain Claim

The Supreme Court stressed that the private respondents’ title traces back to an Original Certificate of Title issued in 1910, which is conclusive and incontestable against the world under the Torrens system. There is a presumption of regularity in the issuance of the certificate, including jurisdiction and absence of fraud. To annul a Torrens certificate on the ground of being void ab initio, proof of lack of jurisdiction and actual fraud is necessary, neither of which was established by petitioners. The Bureau of Forestry certification stating the land was public domain carried no legal weight against the court-issued title and was insufficient to invalidate it. Furthermore, no government official opposed the original registration. The action to annul due to fraud is time-barred, having prescribed after one year from registration. Thus, the petitioners’ claim that the land remained public domain was unfounded.

Supreme Court’s Rejection of Laches and Acquisitive Prescription Claims

The Court reiterated that ownership under Torrens title is imprescriptible, meaning it cannot be lost by prescription or laches. Registered owners have the indefeasible right to eject unlawful occupants regardless of the length of their possession. The petitioners' assertion that the respondents lost their rights by laches or tacit tolerance is untenable. The right to recover possession remains enforceable at any time since the petitioners’ occupancy was without authorization. Invoking laches was effectively an attempt to claim ownership by prescription, which the law expressly prohibits for Torrens-registered lands.

Supreme Court’s Rebuff to Builder in Good Faith Defense

The Court clarified that a builder in good faith is one who unknowingly builds on land believed to be legitimately owned. This status presupposes an absence of knowledge of defects in title at the time of construction. The petitioners, having asserted that the land w

Case Syllabus (G.R. No. 86787)

Case Background and Issue Presented

The case concerns a dispute over possession of certain portions of land located in Calapacuan, Subic, Zambales, with a total area of 1,652 square meters.
Petitioners are in physical possession of the lots in dispute.
The entire parcel of land is registered to private respondents under Transfer Certificate of Title No. T-29018.
The private respondents (registered owners) filed a lawsuit on January 22, 1985, for recovery of possession of the lots, asserting their rights as titled owners.
Petitioners denied the validity of the title, claiming the land was part of the public domain and could not have been registered under the Torrens system.
Additional claims by petitioners included acquisition of ownership by laches, contracts of sale, inheritance, and claim of rights as builders in good faith.

Regional Trial Court Decision

Trial court ruled in favor of plaintiffs (private respondents), affirming their right as registered owners to possession and recovery of the land.
The court emphasized that ownership under the Torrens system grants inherent rights to enjoy, possess, recover, and dispose of the land.
Defendants’ occupancy was declared unlawful and violating plaintiffs’ rights.
Certifications from Bureau of Forestry claiming the land as public domain were given little weight due to lack of legal basis.
When land is registered, it ceases to be public domain and becomes private property.
Tax declarations and payments by defendants were not evidence of ownership and cannot override the registered title.
The court reaffirmed that prescription or acquisitive prescription does not apply to Torrens-titled property.
Judgment ordered defendants to restore possession to the plaintiffs.

Court of Appeals Ruling

On appeal, the Regional Trial Court’s decision was upheld on August 22, 1988.
Motion for reconsideration by petitioners was denied.
The ruling reinforced the principle of title indefeasibility under the Torrens system and the corresponding right of registered owners.

Issues Raised on Appeal to the Supreme Court

Petitioners sought reversal on three primary grounds:
1. The land is public domain and was not registrable under the Torrens system.
2. Petitioners acquired ownership of the lots through laches/acquisitive prescription.
3. Alternatively, petitioners claim to be builders in good faith entitled to Civil Code p