Corpuz v. Agustin

G.R. No. 183822 (January 18, 2012)

Facts:

Ruben C. Corpuz (petitioner) filed a complaint for ejectment against Spouses Hilarion and Justa Agustin (respondents), claiming ownership of two parcels of land in Santa Joaquina, Laoag City, covered by Transfer Certificate of Title (TCT) No. 12980. The properties were originally owned by Elias Duldulao, who sold them to Francisco D. Corpuz, the father of Ruben, in 1951. Francisco allowed the Agustins, who were relatives, to occupy the properties. Despite demands to vacate, the Agustins refused to leave.

Ruben asserted that he had a better right to possess the properties, having received a Deed of Quitclaim from his father on March 15, 1971. In their defense, the Agustins claimed that Francisco Corpuz had sold the properties to them through a Deed of Absolute Sale dated June 5, 1971, for P11,150. The Municipal Trial Court (MTC) ruled in favor of the Agustins, finding that they had established ownership through their long-term possession and the sale from Francisco.

Ruben appealed to the Regional Trial Court (RTC), which affirmed the MTC's decision. The RTC noted that the Quitclaim to Ruben was executed before the Deed of Sale to the Agustins, but the latter's possession was deemed to be in the nature of ownership. Ruben then appealed to the Court of Appeals (CA), which also dismissed his appeal, concluding that the Agustins' possession was not merely tolerated but was based on ownership.

Issues:

1. Whether the Court of Appeals erred in failing to recognize the legal ownership of the petitioner as the basis for his claim to better possession.
2. Whether the Court of Appeals misappreciated the alleged sale in favor of the respondents, leading to a ruling that they had a better right to possession.
3. Whether the Court of Appeals failed to consider relevant jurisprudence, specifically the case of Jacinto Co v. Militar, which was similar to the present case.
4. Whether the Court of Appeals erred in denying the petition for review.

Arguments:

• Petitioner (Ruben C. Corpuz):

  • As the registered owner under TCT No. T-12980, he has a better right to possess the properties.
  • The Agustins' claim of ownership through an unregistered Deed of Sale should not prevail over his registered title.
  • The CA failed to consider the implications of the Jacinto Co case, which supported his position as the titleholder.

• Respondents (Spouses Agustin):

  • They have been in continuous possession of the properties for over 30 years, asserting that their possession is based on ownership from the sale made by Francisco Corpuz.
  • The Quitclaim to Ruben was executed before their Deed of Sale, but the latter was not registered, and they have acted as owners since the sale.
  • The CA correctly ruled that their possession was not merely tolerated but was in the nature of ownership.

Court's Decision and Legal Reasoning:

The Supreme Court denied the petition, affirming the decisions of the lower courts. The Court emphasized that the issue in ejectment cases is primarily about physical possession rather than ownership. It reiterated that while a Torrens title holder is entitled to possession, the nature of possession must be considered.

The Court noted that the Agustins had established their possession as one of ownership, not mere tolerance, and had been in possession for over three decades. The Court also clarified that the petitioner’s knowledge of the Agustins' sale and their long-term possession negated his claim of better right to possession.

The Court distinguished between the rights of a registered owner and the rights of a possessor who claims ownership. It stated that the mere existence of a Torrens title does not automatically grant the titleholder the right to eject a long-term possessor without due process.

The Court also addressed the argument regarding the alleged fraud in the registration of the title, stating that such claims constitute a collateral attack on the Torrens title, which is impermissible in an unlawful detainer case.

Significant Legal Principles Established:

1. In ejectment cases, the primary issue is physical possession, not ownership.
2. A registered title under the Torrens system is indefeasible and cannot be attacked collaterally in summary proceedings.
3. Long-term possession by a party claiming ownership can establish a right to possession that may prevail over a registered titleholder's claim in summary ejectment proceedings.
4. Knowledge of an unregistered interest can equate to registration for the purposes of determining rights in possession.