View full case

SOTERO ROY LEONERO v. SPS. MARCELINO B. BARBA

FACTS:

The case involves a complaint for Quieting of Title and Preliminary Injunction filed by the petitioners against the respondents before the Regional Trial Court (RTC) of Quezon City. The petitioners sought to declare the respondent's Transfer Certificates of Title (TCT) as null and void, claiming that they originated from an Original Certificate of Title (OCT) that had been declared void in a previous case. The respondents, on the other hand, argued that their TCTs were genuine titles issued by the Register of Deeds and were not affected by the previous case. The RTC eventually dismissed the petitioners' complaint, and the petitioners appealed to the Court of Appeals (CA), which affirmed the dismissal. The main issue in this case is whether the CA erred in affirming the dismissal of the complaint without conducting a trial on the merits. The Supreme Court ruled that the dismissal was proper because the petitioners' action was a collateral attack against the respondents' TCTs, which is not allowed by law. The Court also declared that the partial decision on which the petitioners based their claim was already null and void. As a result, the petition was denied.

ISSUES:

  1. Whether the Court of Appeals erred in affirming the Regional Trial Court's dismissal of the complaint for quieting of title without conducting trial on the merits.

  2. Whether the action for quieting of title is a collateral attack against the respondents' Transfer Certificates of Title (TCTs).

RULING:

  1. The Court of Appeals did not err in affirming the Regional Trial Court's dismissal of the complaint for quieting of title without conducting trial on the merits. The court has the discretion to render judgment based on the parties' admissions in their pleadings without the introduction of evidence if there is an insufficiency of factual basis for the action.

  2. The action for quieting of title is a collateral attack against the respondents' Transfer Certificates of Title (TCTs). The validity of a certificate of title cannot be assailed in an action for quieting of title, and an action for annulment of title is the more appropriate remedy.

PRINCIPLES:

  • Certificates of title cannot be subject to collateral attack and can only be altered, modified, or cancelled in a direct proceeding in accordance with the law. (Section 48 of the Property Registration Decree)

  • The issue of whether a title was procured by falsification or fraud should be raised in an action expressly instituted for the purpose, not in an action for quieting of title. (Foster-Gallego v. Galang)

  • The validity of a certificate of title cannot be assailed in an action for quieting of title; an action for annulment of title is the more appropriate remedy to seek the cancellation of a certificate of title. (Vda. de Gualberto v. Go)

  • The Partial Decision issued in Civil Case No. Q-35672 has been declared null and void. (Pinlac v. Court of Appeals)

  • The Torrens system of land registration means that all lots within an estate are titled. (Cañete v. Genuino Ice Company, Inc.)