Case Summary (G.R. No. 93687)
Applicable Law
The case is guided by the principles enshrined in the 1987 Philippine Constitution, as well as pertinent provisions of the Civil Code regarding property and obligations, alongside doctrines concerning the indefeasibility of Torrens titles.
Factual Background
In 1965, Marcelita Co entered into an installment sale agreement for two parcels of land with Andres Gabriel, with payment completed by 1966. Instead of registering the property in her name, the title was placed in the name of her brother, Ruperto Padonan, operating under a trust agreement. Subsequent to the transaction, Ruperto executed various deeds, including a sale of the property in favor of private respondent Eduardo Memije. Despite registering the property, Memije could not take possession as the petitioners occupied it. Various legal disputes ensued over possession and ownership.
Legal Proceedings and Decisions
On multiple occasions, the parties engaged in judicial proceedings seeking recovery of the property, resulting in dismissals largely due to procedural issues regarding venue or improper claims. The Regional Trial Court ruled in favor of private respondents, stating that the petitioners could not validly assert ownership given the registered title held by respondents. Petitioners' appeals were predicated on claims of fraud and ownership that were deemed improper as defenses in the recovery of possession case.
Torrens Title and Indefeasibility
The Court reiterated the doctrine of indefeasibility of Torrens titles, underscoring that titles, once registered, cannot be collaterally attacked outside a direct action challenging their validity. The petitioners’ claims of fraud were thus dismissed due to their failure to institute proper proceedings to annul the sale or the title, confining their arguments to improper claims within the possession action.
Compulsory Counterclaims and Legal Remedies
The Court found that the counterclaims presented by the petitioners failed to meet the criteria for compulsory counterclaims, which are claims arising out of the same transaction as the opposing party's claim. The nature of petitioners' claims resembled an independent action challenging respondents’ title rather than a defense relevant to recovering possession, further justifying the dismissal of their counterclaims.
Good Faith Purchase Considerations
The Court examined whether private respondents acted in bad faith during the acquisition of the property. It rejected the petitioners' arguments that they had prior knowledge
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Background of the Case
- In 1965, Marcelita Co contracted to buy two parcels of land from Andres Gabriel in Malabon, Rizal, on an installment basis, completing payments by 1966.
- To facilitate registration, the final deeds of sale were executed in the name of her brother, Ruperto Padonan, as a trustee, despite Marcelita being the actual purchaser.
- One lot was later sold to Hipolito Tamayo, while the other remained under Ruperto Padonan’s name with a house built upon it.
- On January 28, 1973, Ruperto executed a deed of absolute sale in favor of Marcelita Co and a special power of attorney to Romeo Co.
- The deed of sale in favor of Marcelita was not registered.
- On September 10, 1974, Ruperto sold the other lot to Eduardo Memije, who subsequently faced issues gaining possession of the property due to the Co couple's occupancy.
Procedural History
- A civil case (Civil Case No. C-3489) was filed by Memije for recovery of possession, which was dismissed without prosecution.
- In 1976, Memije sought a writ of possession in the original land registration proceedings, which was initially granted but later set aside by the Supreme Court.
- The Co couple filed Civil Case No. C-11063 to annul the deed of sale and title but was dismissed for improper venue.
- In November 1983, Memije filed Civil Case No. 370-MN against the Co couple to recover possession, where the Co couple raised defenses of ownership and fraud.
Judgment of the Regional Trial Court
- The trial court ruled in favor of Memije on May 18, 1987, ordering the Co couple to vacate and pay compensation and atto