Republic v CA (301 SCRA 366)

Republic v CA (301 SCRA 366)

Facts:

St. Jude’s Enterprises is the registered owner of a parcel of land in Caloocan. In March 1966, this land was subdivided into two lots under subdivision plan (LRC) PSD 55643. The first lot was later found to have expanded its area, this was confirmed by the Land Registration Commission (LRC). St Jude’s then sold the lots to Spouses Santos, Spouses Calaguian, and Lucy Madaya.

In January 1985, Sol Gen Estelito Mendoza filed an action to annul the sales on the lots on the ground that the subdivision plan was null and void because it expanded the area of the land.

The RTC dismissed the complaint. It found that the buyers of the land purchased the lots in good faith and since the titles were registered under the Torrens system, such titles became absolute and irrevocable. Also, even if the Sol Gen proved the expansion of the area, there was no proof of fraud when St. Jude submitted the subdivision plan to the LRC.

The CA affirmed the RTC. Thus, the petition for review.

Issue/s:

Whether or not the gov’t is stopped from questioning the approved subdivision plan.

Held:

                Yes.  While the general rule is that the State can’t be put in estoppel by mistakes of its officials, this is subject to limitations. Where innocent 3^rd persons, relying on the correctness of the certificate of title, acquire rights over the property, courts cannot disregard such rights and cancel the certificate.

                In the case, for nearly 20 years (1966-1985),  the State failed to correct and recover the alleged increase of land area of St. Jude. Also, there was no proof given that the land area was intentionally and fraudulently increased or how fraud was allegedly made. The State’s prolonged inaction is tantamount to laches (the negligence/omission of a right w/in a reasonable time, warranting a presumption that the party entitled to assert it has abandoned or declined to assert it).

                Also, the buyers bought the lots in good faith, relying on the clean certificate of St. Jude. They did not have to go behind the titles to verify the contents or search for hidden defects that could defeat their rights to the lots. The main purpose of the Torrens system is to avoid  conflicts of title and to facilitate transactions by giving the public to rely on the face of a Torrens Title and to dispense the need of inquiring further. It is only fair and reasonable to apply estoppel to avoid injustice to the innocent purchasers for value. Furthermore, Sol Gen didn’t present proof that they bought the lots in bad faith.

*As regards the expansion of the land, the SC said that the “more or less” term used in the surveyor’s findings indicates that the land was not exact. What defines a piece of titled property is not the numerical data, but the boundaries or “metes and bounds” of the property specified in its technical description and showing its limits.

*SC affirmed CA.

Doctrine:  

Where innocent 3^rd persons, relying on the correctness of the certificate of title, acquire rights over the property, courts cannot disregard such rights and cancel the certificate. All persons dealing with registered land may safely rely on the correctness of the title issued. The law/courts do not oblige them to go behind the certificate in order to investigate again the true condition of the property.