VIRGINIA CALALANG, vs. REGISTER OF DEEDS OF QUEZON CITY, ADMINISTRATOR OF NATIONAL LAND TITLES AND DEEDS REGISTRATION ADMINISTRATION, LUCIA DE LA CRUZ, CONSTANCIO SIMANGAN and IGLESIA NI KRISTO.
- G.R. Number: G.R. No. 76265
- Promulgated: 1992-04-22
- Ponente: Gutierrez, Jr., J.
Doctrine
A decree of registration becomes incontrovertible and the certificate of title indefeasible after one year from entry, and a petition for review must be brought within that year (Land Registration Act).
Certificates of title cannot be the subject of collateral attack; they may be altered, modified, or cancelled only in a direct proceeding in accordance with law (Property Registration Decree, Section 48 principle as applied).
To preserve the Torrens system's stability, derivative titles based on a valid reconstituted title should be annulled where necessary to prevent proliferation of null and void derivative titles.
Facts
The petitions involve Lot 671-A of the Piedad Estate in Barrio Culiat, Diliman, and consolidated petitions concern title disputes over that parcel (Lot 671-A being part of Lot 671).
The petitioners are individual lot owners who claim purchases from Amando Clemente in the 1950s and opposed the reconstitution-derived titles.
Lower-court proceedings included intervention by respondent INK and motions to dismiss and for preliminary injunction; administrative reconsideration was denied as issues were litigious and beyond consulta.
This Court previously ruled in related matters, finding INK's title to Lot 671 incontrovertible and indefeasible, and dismissed the petitions for lack of merit.
Issues
Whether the petitioners may collaterally attack the reconstitution-derived titles and question INK's title to Lot 671-A through the instant petitions.
Whether the decree of registration and certificates of title issued under the Land Registration Act have become incontrovertible and indefeasible after the statutory period, barring collateral attack.
Ruling
The Court held petitioners cannot raise anew ownership of Lot 671 through collateral attack because ownership had been finally determined in prior decisions; petitions were dismissed for lack of merit.
The Court affirmed that, after the lapse of the one-year review period under the Land Registration Act, a decree of registration becomes incontrovertible and binding on all persons and cannot be collaterally attacked.
Disposition: The petitions in G.R. Nos. 76265 and 83280 are dismissed for lack of merit; the integrity and stability of the Torrens system require annulment of derivative transfer certificates where appropriate to prevent proliferation of null titles.
Keywords
G.R. No. 76265, G.R. No. 83280, Transfer Certificate of Title No. 16212, dela Cruz v. dela Cruz (130 SCRA 666 [1984]), G. R. No. 61969, action for reconveyance founded on breach of trust, Registrability of documents, consulta case, reconstitution of TCT No. RT-58, validity of sale, Special Civil Action for Certiorari and Prohibition, indispensable party, cancellation proceedings, Civil Case No. Q-49900, injunction suit, Civil Case No. Q-45767, supplemental petition, lucia dela cruz, dela cruz, motion