G.R. No. 262146 - CAVINTI REALTY DEVELOPMENT CORPORATION, VS. NERY CUSTODIO ABLAO AND MARIA CUSTODIO CUYA.D E C I S I O N - Supreme Court E-Library

Ruling

Accordingly, the Court holds that Cavinti Realty is both a real party-in-interest, because its rights will necessarily be affected by the judgment, and an indispensable party, whose participation is required for a valid resolution of the controversy. The Complaint cannot be dismissed on the theory that Cavinti Realty was improperly joined. On the contrary, its joinder was essential, and the rulings of the RTC and the CA in maintaining Cavinti Realty as a party-defendant are procedurally and substantively correct. Prescription and imprescriptibility: Effect of Presidential Decree No. 1529 and the Statute of Limitations The Court now addresses the issue of prescription, which Cavinti Realty vigorously invokes. It argues that Nery and Maria's action, instituted in 2014, was filed far too late34 years after the issuance of Dos Lagos' title in 1980. Cavinti Realty relies on Section 32 of Presidential Decree No. 1529, [47] otherwise known as the Property Registration Decree, which expressly imposes a time bar on challenges to decrees of registration. The relevant portion of the provision states: Section 32. Review of decree of registration; Innocent purchaser for value. The decree of registration shall not be reopened or revised by reason of absence, minority, or other disability of any person adversely affected thereby, nor by any proceeding in any court for reversing judgments, subject, however, to the right of any person deprived of land or any interest therein by actual fraud to file in the proper Court of First Instance a petition for reopening and review of the decree within one year from and after the date of entry of such decree of registration, but in no case shall such petition be entertained by the court where an innocent purchaser for value has acquired the land or any interest therein whose rights may be prejudiced. Whenever the phrase "innocent purchaser for value" or an equivalent phrase occurs in this Decree, it shall be deemed to include an innocent lessee, mortgagee, or other encumbrancer for value. Upon the expiration of said period of one year, the decree of registration and the certificate of title issued shall become incontrovertible. Any person aggrieved by such decree of registration may pursue his remedy by action for damages against the applicant or any other person responsible for the fraud. Under this provision, once an original decree of registration under the Torrens system is issued and the one-year period lapses, the decree may no longer be reopened or set aside, and the corresponding title becomes incontrovertible and indefeasible. The only exception lies within the one-year period, where an aggrieved party may petition for reopening upon proof that the decree was secured through actual fraud. Even then, such relief is unavailable if the rights of an innocent purchaser for value would be prejudiced. Beyond the one-year period, the sole recourse of an aggrieved party is confined to an action for damages against the pa