Back to Search
JurisprudenceG.R. NO. 159292 -

G.R. NO. 159292 - SPOUSES RICHARD B. PASCUAL AND CRISTINA D. PASCUAL, VS. SPOUSES REYNALDO P. CORONEL AND ASUNCION MALIG CORONEL.DECISION - Supreme Court E-Library

Cited Laws

RA 640RA 114,RA 220,RA 80,RA 305,RA 236,RA 539,RA 317,
Share:

Decision

Ruling

Accordingly, as far as this Court is concerned, these findings are already final. In any case, we sustain the appellate court's finding that the respondents have the better right to possess the subject property. As opposed to the unregistered deeds of sale, the certificate of title certainly deserves more probative value. Indeed, a Torrens Certificate is evidence of indefeasible title of property in favor of the person in whose name appears therein'such holder is entitled to the possession of the property until his title is nullified. [24] The petitioners, however, insist that the deeds of sale deserve more credence because they are valid contracts that legally transferred ownership of the property to Melu-Jean. They argue that (a) the 1975 Deed, being a public document, is presumed to be valid and there was no evidence sufficient to overturn such presumption or show that it was simulated; (b) the fact that the person who notarized the said deed of sale is not commissioned as a notary public has no bearing on its validity; (c) registration of the deed of sale was not necessary to transfer ownership; (d) Melu-Jean is not guilty of laches in asserting her ownership over the property since she is actually in possession of the property through the petitioners; and (e) the filing of the annulment case is an admission that the two deeds of sale are merely voidable, or valid until annulled. However, it should be noted that the CA merely affirmed the power of the trial court to provisionally resolve the issue of ownership, which consequently includes the power to determine the validity of the deeds of sale. As previously stated, such determination is not conclusive, and the issue of ownership and the validity of the deeds of sale would ultimately be resolved in the case for annulment of the deeds of sale. Even if we sustain the petitioners' arguments and rule that the deeds of sale are valid contracts, it would still not bolster the petitioners' case. In a number of cases, the Court had upheld the registered owners' superior right to possess the property. In Co v. Militar, [25] the Court was confronted with a similar issue of which between the certificate of title and an unregistered deed of sale should be given more probative weight in resolving the issue of who has the better right to possess. There, the Court held that the court a quo correctly relied on the transfer certificate of title in the name of petitioner, as opposed to the unregistered deeds of sale of the respondents. The Court stressed therein that the Torrens System was adopted in this country because it was believed to be the most effective measure to guarantee the integrity of land titles and to protect their indefeasibility once the claim of ownership is established and recognized. [26] Likewise, in the recent case of Umpoc v. Mercado, [27] the Court declared that the trial court did not err in giving more probative weight to the TCT in the name of the decedent vis-à-vis the contested u