This case involves a dispute between the National Housing Authority (NHA) and the heirs of Spouses Laurito over ownership of a parcel of land in Carmona, Cavite, with both parties presenting different Transfer Certificates of Title (TCTs) derived ultimately from the same parent title but registered at different times and through different processes (transfer vs. administrative reconstitution). The Supreme Court affirmed the lower courts' decisions upholding the title of the Spouses Laurito's heirs, ruling that their title, registered earlier in time (1956), prevails over NHA's titles which originated from a later, dubious administrative reconstitution (1960) of an already cancelled parent title. The Court also denied a late petition-in-intervention filed by the heirs of Rufina Manarin.
Primary Holding
Where two certificates of title are issued to different persons covering the same land, the certificate of title issued earlier in date must prevail, and the reconstitution of a title does not determine ownership nor grant priority based merely on the date of reconstitution, especially when the reconstitution itself is dubious and pertains to a title already cancelled prior to the reconstitution.
Background
The case arose from conflicting claims of ownership over Lot F-3 of subdivision plan Psd-12274 in Carmona, Cavite. The heirs of Spouses Laurito based their claim on TCT No. T-9943 registered in 1956 (later reconstituted as RT-8747 in 1962), derived from TCT No. T-8237. Petitioner NHA based its claim on TCT Nos. T-3717 and T-3741, derived through a series of transfers originating from an alleged administrative reconstitution of the same parent title, TCT No. T-8237, in 1960 (as RT 3909) and subsequent subdivisions/transfers starting in 1960.
History
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Respondents (Heirs of Laurito) filed a complaint for quieting of title, annulment of title, and recovery of possession against NHA in the RTC of Bacoor, Cavite (Civil Case No. BCV-2001-95).
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RTC rendered a Decision (May 27, 2004) confirming respondents' ownership, declaring NHA's titles null and void, and ordering NHA to vacate or pay the property's value.
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NHA appealed the RTC decision to the Court of Appeals (CA-G.R. CV No. 86484).
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CA rendered a Decision (November 26, 2009) affirming the RTC decision in toto.
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CA denied NHA's motion for reconsideration (March 17, 2010).
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NHA filed a Petition for Review under Rule 45 before the Supreme Court (G.R. No. 191657).
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Heirs of Rufina Manarin filed a motion for petition-in-intervention during the pendency of the Supreme Court case.
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Supreme Court rendered its Decision (July 31, 2017) denying NHA's petition and the petition-in-intervention, affirming the CA decision.
Facts
- The disputed property is Lot F-3 (224,287 sq m) in Carmona, Cavite, originally covered by TCT No. T-8237 registered under Rufina Manarin.
- Respondents' parents, Spouses Domingo Laurito and Victorina Manarin, acquired Lot F-3, and TCT No. T-9943 was issued in their names on September 7, 1956, cancelling TCT No. T-8237.
- Spouses Laurito mortgaged the property to PNB in 1956 and redeemed it in 1977.
- The Register of Deeds (RD) of Cavite burned down in 1959.
- Spouses Laurito administratively reconstituted their title based on the owner's duplicate, resulting in TCT No. (T-9943) RT-8747 issued on March 23, 1962. This title remains uncancelled.
- Respondents, upon their parents' death, continued paying taxes and later discovered the property was subdivided into Lot F-3-A and F-3-B and registered under NHA (TCT Nos. T-3717 and T-3741).
- NHA claims its titles originated from the administrative reconstitution of TCT No. T-8237 on February 5, 1960 (as RT 3909), which was allegedly subdivided on the same day into Lots F-3-A (TCT T-943 for Santos) and F-3-B (TCT T-944).
- NHA traces TCT T-3717 (Lot F-3-A) through Santos (T-943, Feb 5, 1960), Cabreira (T-984, Feb 16, 1960), Corpus (T-3445, Aug 7, 1961), finally to People's Homesite and Housing Corporation (NHA's predecessor) on September 22, 1961.
- NHA traces TCT T-3741 (Lot F-3-B) through Spouses Lope Gener (T-1859, Aug 22, 1960, from T-944), finally to PHHC on September 29, 1961.
- The RTC and CA found that the Lauritos' original title (T-9943) was registered earlier (1956) than NHA's earliest derivative titles (1960) and that NHA's source reconstitution (RT 3909 in 1960) pertained to a title (T-8237) already cancelled in 1956.
- Heirs of Rufina Manarin filed a petition-in-intervention before the Supreme Court, claiming the subject property is part of a larger parcel covered by TCT No. T-2409 in Rufina's name, registered May 18, 1956, which they judicially reconstituted in 2005.
Arguments of the Petitioners
- NHA argued that its derivative titles (T-943 and T-1859) were registered in 1960, earlier than the administrative reconstitution date (March 23, 1962) of the Spouses Laurito's title (RT-8747), thus giving NHA priority.
- NHA contended it was an innocent purchaser for value, relying on the Torrens titles of its predecessors (Corpus and Spouses Gener), and was not required to look beyond the certificates of title.
- NHA asserted that the mortgage of Lot F-3-B by Spouses Gener in 1961 proved the existence and validity of its derivative title.
- NHA questioned the RTC's valuation of the property as hearsay.
Arguments of the Respondents
- Respondents (Heirs of Laurito) argued that their parents' title (TCT No. T-9943) was registered on September 7, 1956, long before NHA's earliest derivative titles were registered in 1960, thus their title should prevail under the principle of "prius tempore, potior jure".
- Respondents maintained that the administrative reconstitution of their title in 1962 (RT-8747) was valid, based on the owner's duplicate certificate, and merely restored the title already existing since 1956.
- Respondents contended that NHA's titles were derived from a spurious or void administrative reconstitution (RT 3909) of TCT No. T-8237 in 1960, as T-8237 had already been cancelled in 1956 when T-9943 was issued to the Spouses Laurito.
- Respondents argued NHA was not a buyer in good faith due to numerous red flags surrounding its titles, including the rapid, successive transfers and questionable reconstitutions.
- Respondents (regarding intervention) argued the petition-in-intervention was filed too late and would cause undue delay.
Issues
- Whether the petition-in-intervention filed by the heirs of Rufina Manarin should be granted.
- Whether the NHA or the heirs of Spouses Laurito have a better right over the subject property (Lot F-3).
Ruling
- The petition-in-intervention was denied because it was filed only before the Supreme Court, well after the RTC rendered judgment, violating the timeliness requirement under Rule 19, Section 2, and because the intervenors failed to sufficiently establish their legal interest.
- The Supreme Court denied NHA's petition and affirmed the CA decision, holding that the heirs of Spouses Laurito have a better right to the property.
- The Court applied the rule "prius tempore, potior jure" (first in time, stronger in right), stating that the Lauritos' title, registered in 1956, prevails over NHA's derivative titles, the earliest of which were registered only in 1960.
- The Court clarified that reconstitution of title does not determine or vest ownership; it merely restores a lost or destroyed title to its original form. The date of reconstitution (1962 for Lauritos) does not override the original date of registration (1956).
- The Court found NHA's chain of title dubious, originating from an administrative reconstitution (RT 3909 in 1960) of a parent title (T-8237) that was already cancelled in 1956. Such reconstitution was irregular and void.
- The Court ruled that NHA could not be considered a buyer in good faith, as the circumstances surrounding its acquisition and the questionable nature of its predecessors' titles (rapid transfers, reconstitutions before issuance) should have put it on guard, especially given its mandate and public function requiring greater prudence.
- The Court upheld the valuation of the property determined by the lower courts, as NHA failed to object timely during trial.
Doctrines
- Prius Tempore, Potior Jure (First in Time, Stronger in Right): Definition: When there are conflicting rights over the same property, the person with the earlier right generally prevails. Application: The Court applied this principle to rule that the Lauritos' title, registered in 1956, had priority over NHA's titles derived from registrations starting in 1960.
- Indefeasibility of Torrens Title: Definition: A certificate of title issued under the Torrens system is generally conclusive evidence of ownership and cannot be collaterally attacked. Application: While acknowledged, this was subordinate to the "prius tempore" rule where two titles exist for the same land. The earlier valid title prevails, and the later title, derived from a void reconstitution, is null.
- Reconstitution of Title (Nature and Effect): Definition: Reconstitution restores a lost or destroyed certificate of title to its original form and condition but does not determine or adjudicate ownership. Application: The Court held that the date of reconstitution of the Lauritos' title (1962) was irrelevant to priority; the original registration date (1956) governed. NHA could not claim priority based on its derivative titles existing before the Lauritos' reconstitution date.
- Buyer in Good Faith: Definition: One who buys property without notice that some other person has a right to or interest in such property and pays a full and fair price for the same at the time of such purchase or before he has notice of the claim or interest of some other person in the property. Application: The Court found NHA was not a buyer in good faith due to the suspicious circumstances surrounding its titles (void reconstitution source, rapid successive transfers), stating NHA could not close its eyes to facts that should prompt investigation.
- Intervention (Rule 19): Definition: A remedy allowing a third party with legal interest to join an existing litigation, permissible only before judgment by the trial court, subject to the court's discretion, and provided it does not unduly delay proceedings. Application: The petition-in-intervention by Rufina Manarin's heirs was denied for being filed extremely late (only at the Supreme Court stage) and for failing to clearly establish the required legal interest.
- Registration as the Operative Act: Definition: Under the Property Registration Decree, it is the act of registration in the public registry that binds the land and third persons. Application: This principle underscores the importance of the date of registration in determining priority between conflicting titles.
Key Excerpts
- "The rule is that where two certificates of title are issued to different persons covering the same parcel of land in whole or in part, the earlier in date must prevail as between the original parties and, in case of successive registration where more than one certificate is issued over the land, the person holding title under the prior certificate is entitled to the property as against the person who relies on the second certificate."
- "The reconstitution of a certificate of title denotes restoration in the original form and condition of a lost or destroyed instrument attesting the title of a person to a piece of land... Reconstitution does not pass upon the ownership of the land covered by the lost or destroyed title."
- "Reconstitution is not and should not be made synonymous to the issuance of title. When reconstituting, a new title is not thereby issued; rather, the title alleged to have been previously issued but is now lost or destroyed, is merely reproduced to reflect the way it was before."
- "[A] reconstituted title obtained by means of fraud, deceit or other machination is void ab initio as against the party obtaining the same and all persons having knowledge thereof." (Quoting Sec. 11, R.A. 6732).
- "Well-settled is the rule that a purchaser or mortgagee cannot close his eyes to facts which should put a reasonable man upon his guard, and then claim that he acted in good faith under the belief that there was no defect in the title of his vendor or mortgagor."
- "NHA's title undoubtedly came from a dubious source exhibiting badges of spuriousness and hence, could not have transferred a better right in favor of NHA. Indeed, the spring cannot rise higher than its source."
Precedents Cited
- Iglesia ni Cristo v. CFI of Nueva Ecija (1983): Cited for the rule that the earlier certificate of title prevails when two titles cover the same land.
- Director of Lands v. CA (1981): Also cited for the principle that the earlier title prevails in case of overlapping titles.
- Realty Sales Enterprise, Inc. v. Intermediate Appellate Court (1987): Cited for the rule that the holder of the prior certificate, or one whose claim derives from the holder of the earliest certificate, is entitled to the land.
- Po Sun Tun v. Price and Provincial Government of Leyte (1929): Cited to define registration in its juridical aspect as the entry made in a public registry.
- Republic v. Tuastumban (2009): Cited for defining the purpose of reconstitution of title.
- Heirs of De Guzman Tuazon v. Court of Appeals (2004): Cited for the principle that reconstitution does not determine ownership.
- Republic of the Philippines v. Vergel De Dios (2011): Referenced regarding the procedure for issuing the owner's duplicate after reconstitution under R.A. 26.
- Hi-Tone Marketing Corporation v. Baikal Realty Corporation (2004): Cited for defining intervention as an ancillary remedy.
- Ongco v. Dalisay (2012): Cited regarding the rationale for the time limit on intervention (before trial court judgment).
Provisions
- Rules of Court: Rule 45 (Petition for Review on Certiorari); Rule 19, Sections 1 and 2 (Intervention - Who may intervene; Time to intervene).
- Republic Act No. 26: Section 16 (Procedure for Reconstitution of Torrens Certificates of Title Lost or Destroyed - Issuance of owner's duplicate after reconstitution).
- Republic Act No. 6732: Section 11 (Act Allowing Administrative Reconstitution - Voidness of titles obtained through fraud).
- Presidential Decree No. 1529 (Property Registration Decree): Section 51 (Conveyance and other dealings by registered owner; Registration as the operative act to affect third persons).
- Executive Order No. 90 (1986): Referenced regarding NHA's mandate.
- Presidential Decree No. 757 (1975): Referenced regarding NHA's mandate in housing development.