VSD REALTY v. UNIWIDE SALES

FACTS:

The petitioner, VSD Realty and Development Corporation (VSD), filed a complaint against respondent Dolores Baello and Uniwide Sales, Inc., seeking the nullification of Transfer Certificate of Title (TCT) No. (35788) 12754 in Baello's name. VSD claimed to be the rightful owner of the property covered by TCT No. 35788, which they acquired from Felisa Bonifacio, the registered owner at the time. VSD presented evidence to support their claim, including their own title, TCT No. 275312. Uniwide, on the other hand, asserted that they were not the owners of the property but merely lessees. During settlement discussions, Uniwide identified Baello as the owner of the property.

The trial court ruled in favor of VSD, declaring TCT No. 35788 null and void and ordering Baello and Uniwide to transfer and return the property to VSD. The trial court also awarded damages and attorney's fees to VSD. Respondents filed motions for reconsideration, which were denied. They appealed to the Court of Appeals, which dismissed VSD's complaint, stating that Baello's title enjoys the presumption of validity and that VSD failed to prove that the title was spurious. The Court of Appeals also denied VSD's cross-claim.

ISSUES:

  1. Whether the burden of proof shifted to respondents Baello and Uniwide.

  2. Whether petitioner's allegation regarding the issuance of two titles over the same piece of land was misconstrued.

  3. Whether the Court of Appeals erred in treating petitioner's complaint as one only for annulment of title and not reconveyance.

  4. Whether respondent Baello's title is spurious.

  5. Whether respondent Uniwide is a lessor in good faith.

  6. Whether the title of respondent Baello covers the same property as that covered by petitioner's title.

  7. Whether the petitioner is entitled to recover the possession of the subject property.

  8. Whether reconveyance is in order.

  9. Whether the technical description presented by defendant Baello is admissible as proof of her claim to the property.

  10. Whether petitioner VSD has proven its title over the property.

  11. Whether the title of respondent Dolores Baello can be nullified.

  12. Whether petitioner is entitled to just and reasonable compensation for the occupancy and use of its land.

  13. Whether petitioner is entitled to attorney's fees.

RULING:

  1. The burden of proof did not shift to respondents Baello and Uniwide. Each party must establish their own case.

  2. The Court holds that petitioner's allegation regarding the issuance of two titles over the same piece of land was not misconstrued.

  3. The Court of Appeals erred in treating petitioner's complaint as one only for annulment of title and not reconveyance.

  4. Respondent Baello's title is not spurious.

  5. Respondent Uniwide is not a lessor in good faith.

  6. The claim of Baello that her title covers the same property as that covered by petitioner's title cannot be given credence because of the disparity in the lot description and the technical description. The technical description of the land covered by Baello's title shows that it is not the same as the technical description of the land covered by petitioner's title.

  7. Petitioner is entitled to recover the possession of the subject property as it has proven its title over the property and the identity of the property.

  8. Reconveyance is in order as petitioner has complied with the requisites of reconveyance under Article 434 of the Civil Code.

  9. The Court held that the technical description submitted by defendant Baello was not established by any competent witness and, therefore, cannot be considered as proof of her claim to the property.

  10. The Court ruled that petitioner VSD has proven its title over the property by presenting its title, TCT No. T-285312, which describes the metes and bounds of the subject lot covered therein.

  11. The title of respondent Dolores Baello cannot be nullified, as petitioner failed to present proof that the title was issued through fraud. Moreover, Baello's title covers a different property from that described in petitioner's title.

  12. Petitioner is entitled to just and reasonable compensation for the occupancy and use of its land. The trial court ordered Baelo and Uniwide to pay compensation of P1,200,000.00 per month, but the amount was not supported by evidence. The Court determined a reasonable compensation to be the monthly rental stated in the lease contract between Uniwide and Baello, which is P58,333.30. This amount shall earn interest at six percent (6%) per annum from the filing of the complaint until the award becomes final and executory, and twelve percent (12%) per annum from the date the award becomes final and executory until fully paid.

  13. The trial court erred in awarding attorney's fees without stating the basis for such award. Therefore, the award of attorney's fees to petitioner is deleted.

PRINCIPLES:

  • A Torrens title is generally a conclusive evidence of ownership and carries a presumption of validity.

  • A certificate of title may be annulled or cancelled under certain grounds, such as fraud, prior issuance of a Torrens title, land reserved for public purposes, or violation of conditions for its issuance.

  • In civil cases, the burden of proof rests on the party making allegations.

  • Each party must establish their own case. The burden of proof does not shift.

  • A comparison of technical descriptions on titles can help determine if they cover the same property.

  • To successfully maintain an action to recover the ownership of a real property, the person claiming a better right to the property must prove the identity of the land claimed and his title thereto.

  • In an accion reinvindicatoria, the person claiming a better right to the property must first fix the identity of the land by describing the location, area, and boundaries thereof.

  • The technical description of a titled lot registered under the Torrens system should appear on the face of the title.

  • The person who claims a better right to the property must rely on the strength of his title and not on the weakness of the defendant's claim.

  • In an action to recover real property, the plaintiff must rely on the strength of his title, not on the weakness of the defendant's title. The burden of proof lies on the party who substantially asserts the affirmative of an issue. (Hutchison v. Buscas)

  • Article 448 of the Civil Code, which allows full reimbursement of useful improvements and retention of the premises until reimbursement is made, applies only to a possessor in good faith, i.e., one who builds on land with the belief that he is the owner thereof. It does not apply where one's only interest is that of a lessee. (Parilla v. Pilar)

  • Title of respondent cannot be nullified without proof of fraud.

  • Just and reasonable compensation is based on the monthly rental in the lease contract.

  • The basis for granting attorney's fees must be stated.