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.

ABADIANO V. MARTIR (REMEDIAL)

It is well settled that the findings of fact of the trial court, especially when affirmed by the CA, are accorded the highest degree of respect, and generally will not be disturbed on appeal. such findings are binding and conclusive on the Court. The jurisdiction of the Court is limited only to review of ERRORS OF LAW, unless the case falls under the recognized exceptions, namely:

1. when the findings are grounded entirely on speculation, surmises, or conjectures;
2. when the inference made is manifestly mistaken, absurd, or impossible;
3. when there is grave abuse of discretion;
4. when the judgment is based of a misapprehension of facts;
5. when the findings of fact are conflicting;
6. when in making its findings, the CA went beyond the issues of the case, or its findings are contrary to the admissions of both the appellant and the appellee;
7. when the findings are contrary to those of the trial court;
8. when the findings are conclusions without citation of specific evidence on which they are based;
9. when the facts set forth in the petition as well as in the petitioner's main and reply briefs are not disputed by the respondent; and
10. when the findings of fact are premised on the supposed absence of evidence and contradicted by the evidence on record.

In the present case, we find that the trial court based its judgment on a misapprehension of facts, as well as on the supposed absence of evidence which is contradicted by the records.

Considering that the action is one for quieting of title and respondents anchored their claim to the property on the disputed Compra Y Venta, we find it necessary to say that it was incumbent upon the trial court to have resolved first the issue of the document's due execution and authenticity before determining its validity.

Respondents attached only a photocopy of the Compra Y Venta to their complaint and alleged that the original of said document was in the Register of Deeds, that they tried to obtain a copy but was refused. No other evidence but these assertions were presented.

The Rule states that when the original document is unavailable, has been lost or destroyed, or cannot be produces in court, the offeror, upon proof of its execution or existence and the cause of its unavailability without bad faith on his part, may prove its contents by a copy, or by a recital of its contents in some authentic document, or by the testimony of witnesses in the order stated.

In the case at bar, respondents failed to establish that the offer in evidence of the document was made in accordance with any of the exceptions allowed under the Rule, and yet the trial court accepted the document as genuine and proceeded to determine its validity based on such assumption.

The trial court likewise brushed aside the apparent defect that the document presented contained the same notarial inscription as the Agreement on Partition. We stress that a notarial document is evidence of the facts in the clear unequivocal manner therein expressed and has in its favor the presumption of regularity.

In this case, while it is true that the error in the notarial inscription would not have invalidated the sale - if indeed it took place - the same error would have meant that the document cannot be treated as a notarial document and thus, not entitled to the presumption of regularity. The document would be taken out of the realm of the public documents whose genuineness and due execution need not be proved.

Under the Property Registration Decree, no title to register land in derogation of the title of the registered owner shall be acquired by prescription or adverse possession. Indefeasibility and imprescriptibility are the cornerstones of land registration proceedigns. Barring any mistake or use of fraud in the procurement of title, owners may rest secure on their ownership and possession once their title is registered under the protective mantle on the Torrens system.

Nonetheless, even if a Torrens title is indefeasible and imprescriptible, the registered landowner may lose his right to recover the possession of his registered property by reason of laches.

The four basic elements of laches are:

1. conduct on the part of the defendant, or of one under whom he claims, giving rise to the situation of which complaint is made and for which the complaint seeks a remedy;
2. delay on asserting the complainant's rights, the complainant having had knowledge or notice of the defendant's conduct and having been afforded an opportunity to institute suit; lack of knowledge or notice on the part of the defendant that the complainant would assert the right on which he bases his suit; and
3. injury or prejudice to the defendant in the event relief is accorded to the complainant or the suit is not held to be barred.

The reason for the rule is not simply the lapse of time during which the neglect to enforce the right has existed, but the changes of condition which may have arisen during the period in which there has been neglect.

Though laches applies even to imprescriptible actions, its elements must be proved positively. Laches is evidentiary in nature and cannot be established by mere allegations in the pleadings.

Based on the foregoing, we hold that petitioner is not guilty of laches. The evidence on record does not support such finding.

Petitioner had reasonable ground to believe that the property, being still in the name of his predecessor-in-interest, continued to be theirs, especially considering that the annotation of the purported sale was done only in 1982. According to petitioner, his father had told him that his inheritance was in the possession of their uncle, who knew likewise that the property was theirs.

That the petitioner and his co-heirs waited until the death of said uncle to try and occupy the land is understandable. They had to be careful about the actions they took, lest they sow dissent within the family. Further, they knew that their parents revered the uncle.

The Court has recognized that this reaction cannot be characterized as such delay as would amount to laches.

In sum, we find that petitioner is not guilty of such neglect or inaction as would bar his claim to the property in question. In contrast, it is most telling that respondents, who are claiming to have been in possession of the property by virtue of an alleged duly constituted sale for almost 60 years. have themselves failed within that long period to have the same property transferred in their name or even only to have the sale annotated on the title of the property.

SAN ROQUE REALTY V. REPUBLIC (EXPROPRIATION, LACHES, LAND REGISTRATION)

In Republic v. Lim, we emphasized that no piece of land can be finally and irrevocably taken from an unwilling owner until compensation in paid.

Without FULL PAYMENT OF JUST COMPENSATION, there can be no transfer of title from the landowner to the expropriator. Thus, the Republic's failure to pay just compensation precluded the perfection of its title over the lot sought to be expropriated. In fact, we went even further and recognized the right of the unpaid owner to recover the property if within 5 years from the decision of the expropriation court, the expropriator fails to effect payment of just compensation.

Time and again, we have declared that EMINENT DOMAIN cases are to be strictly construed against the expropriator. The payment of just compensation for private property taken for public use is an indispensable requisite for the exercise of the State's sovereign power of eminent domain. Failure to observe this requirement renders the taking ineffectual, notwithstanding the avowed public purpose. To disregard this limitation on the exercise of governmental power to expropriate is to ride roughshod over private rights.

From the records of this case and our previous findings in the related case, the Republic manifestly failed to present clear and convincing evidence of full payment of just compensation and receipt thereof by the property owners. More importantly, if the Republic had actually made full payment of just compensation, in the ordinary course of things, it would have led to the cancellation of title, or at least, the annotation of the lien in favor of the government on the certificate of title.

The registration with the Registry of Deeds of the Republic's interest arising from the exercise of it's power or eminent domain is in consonance with the Land Registration Act. There is no showing that the Republic complied with the aforesaid registration requirement.

From the foregoing, it is clear that it was incumbent upon the Republic to cause the registration of the subject properties in its name or record the decree of expropriation on the title. Yet, not only did the Republic fail to register the subject properties in its name, it failed to do so for 56 years.

This brings us to the question: Is the Republic, by its failure or neglect to assert its claim, barred by laches?

LACHES is the failure or neglect, for an unreasonable and unexplained length of time, to do that which by exercising due diligence could or should have been done earlier; it is negligence or omission to assert a right within a reasonable time, warranting a presumption that the party entitled to assert it either has abandoned it or declined to assert it.

The general rule is that the State cannot be put in estoppel or laches by the mistakes or errors of its officials or agents. This rule, however, admits of exceptions. One exception is when the strict application of the rule will defeat the effectiveness of a policy adopted to protect the public, such as the Torrens system.

Very telling of the Republic's silence and inaction, whether intentional or by sheer negligence, is the testimony of Infante, the Republic's witness in the proceedings before the RTC, testifying that several surveys were conducted on a number of expropriated lots, which surveys showed that the subject lot was still registered in the name of the original owners. As such, Infante recommended in his report that legal action be taken. Yet despite aforesaid recommendation, title to subject lot remained registered in the name of the original owners, ans subsequently, its transferees. This silence and unexplained inaction by the Republic clearly constitute laches.

The trial court correctly held that title registered under the Torrens system is notice to the whole world. Every person dealing with registered land may safely rely on the correctness of its certificate of title and the law will not oblige him to go beyond what appears on the face thereof to determine the condition of the property.

An innocent purchaser for value is one who, relying on the certificate of title, bought the property from the registered owner, 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 ha has notice of the claim or interest of some other person in the property.

CAMITAN V. FIDELITY INVESTMENT (COUNSEL'S ACT BINDS CLIENT, TORRENS TITLE)

Every counsel has the implied authority to do all acts which are necessary or incidental to the prosecution and management of the suit in behalf of his client. Any act performed by counsel within the scope if his general and implied authority is, in the eyes of the law, regarded as the act of the client himself. Consequently, the mistake or negligence of the client's counsel, which may result in the rendition of an unfavorable judgment, generally binds the client. To rule otherwise would encourage every defeated party, in order to salvage his case, to claim neglect or mistake on the part of his counsel. Then, there would be no end to litigation, as every shortcoming of counsel could be the subject of challenge by his client through another counsel who, if he is also found wanting, would likewise be disowned by the same client through another counsel, and so on, ad infinitum.

This rule admits of EXCEPTIONS, i.e., where the counsel's mistake is so great and serious that without due process of law:

1. the client is deprived of his day in court; or
2. the client is deprived of his property.

In these cases, the client is not bound by his counsel's mistakes and the case may even be reopened in order to give the client another chance to present his case. In the case at bar, however, these exceptional circumstances do not obtain.

At this point, the SC reiterated the principle that possession of a lost owner's duplicate copy of a certificate of title is not necessarily equivalent to ownership of the land covered by it. Registration of real property under the Torrens system does not create or vest title because it is not a more of acquiring ownership. The certificate of title by itself, does not vest ownership; it is merely an evidence of title over the particular property described therein.