EAGLE V. REPUBLIC (REMEDIAL)

The body of the pleading or complaint determines the nature of an action, not its title or heading. This is because the complaint must contain a concise statement of the ultimate facts constituting the plaintiff's cause of action and specify the relief sought. Although denominated as an Action for Annulment of Judgment and Cancellation of Decree and Titles, the complaint is not an action for annulment of judgment under Rule 47, but a case for cancellation of void titles.

ANNULMENT OF JUDGMENT is a remedy against a final and executory judgment. Therefore, a necessary allegation in the complaint would be that there was in fact a judgment that has been issued by the trial court, which judgment has become final. Here, the Complaint does not contain any averment to such effect. On the contrary, the Complaint consistently mentions that the Medina Decision, upon which OCT No. 129 was issued, is a fake document. From the allegations in the Complaint, it is evident that the action is mainly for the declaration of nullity of the certificated of title issued as a result of the fake court decision. This is an action incapable of pecuniary estimation, hence, the RTC properly assumed jurisdiction.

The principle of INDEFEASIBILITY OF A TORRENS TITLE does not apply where fraud attended the issuance of the title. The Torrens title does not furnish a shield for fraud. as such, a title issued based on void documents may be annulled. Moreover, elementary is the rule that prescription does not run against the State and its subdivisions.

Case law has it that he who alleges that he is a purchaser in good faith and for value of registered land bears the onus of proving such statement. This burden is not discharged by involving the ordinary presumption of good faith. Petitioner failed to discharge this burden.

Indeed, the general rule is that a purchaser may rely on what appears on the face of a certificate of title. He may be considered a purchaser in good faith even if he simply examines the latest certificate of title. An exception to this rule is when there exist important facts that would create suspicion in an otherwise reasonable man to go beyond the present title and to investigate those that preceded it. The presence of anything which excites or arouses suspicion should then prompt the vendee to look beyond the certificate and investigate the title of the vendor as appearing on the face of said certificate. One who falls within the exception can neither be denominated as innocent purchaser for value nor a purchaser in good faith, hence, does not merit the protection of the law.

Moreover, petitioner is a corporation engaged in the real estate business. A corporation engaged in the buying and selling of real estate is expected to exercise a higher standard of case and diligence in ascertaining the status and condition of the property subject of its business transaction. Similar to investment and financing corporations, it cannot simply rely on an examination of a Torrens certificate to determine what the subject property, looks like as its condition is not apparent in the document.