GR 91797; (August, 1991) (Digest)
G.R. No. 91797 ; August 28, 1991
WIDOWS AND ORPHANS ASSOCIATION, INC., petitioner, vs. COURT OF APPEALS and ORTIGAS & COMPANY LIMITED PARTNERSHIP, respondents.
FACTS
Petitioner Widows and Orphans Association, Inc. (WIDORA) filed an application for original registration of a 156-hectare parcel of land in Quezon City, claiming ownership derived from Titulo de Propriedad Numero 4136 under the name of Mariano San Pedro y Esteban. Private respondent Ortigas & Company Limited Partnership (Ortigas) moved to dismiss the application, asserting that the land was already registered under the Torrens System in its name under Transfer Certificates of Title (TCT) Nos. 77652 and 77653. Ortigas argued the trial court lacked jurisdiction over land already covered by Torrens titles.
The trial court denied Ortigas’s motion to dismiss. It found that Ortigas’s TCTs appeared to be derived from Original Certificate of Title (OCT) No. 337 and related titles pursuant to Decree No. 1425. The court noted discrepancies, however, as Decree No. 1425 covered only about 17 hectares in Sta. Ana, Manila, not the 156 hectares in Quezon City applied for by WIDORA. The trial court thus declared Ortigas’s TCTs null and void for not being proper derivatives of a valid decree and proceeded with WIDORA’s application.
ISSUE
Whether the trial court correctly assumed jurisdiction over WIDORA’s application for registration despite Ortigas’s claim of prior existing Torrens titles.
RULING
No. The Supreme Court reversed the Court of Appeals and the trial court, ruling that the trial court had no jurisdiction to entertain the application. The core legal principle is that a court cannot exercise jurisdiction over an application for original registration of land already covered by a Torrens certificate of title. The Torrens System aims to guarantee the indefeasibility of title, and a Torrens title, once registered, serves as conclusive evidence of ownership. The proper remedy for a party claiming ownership over land already registered under another’s name is not an original registration proceeding but an action for reconveyance or for the nullification of the existing title.
The trial court erred in declaring Ortigas’s TCTs null and void within the context of WIDORA’s registration application. Such a declaration constitutes a collateral attack on the titles, which is prohibited by law. A Torrens title can only be challenged in a direct proceeding expressly instituted for that purpose. Since Ortigas presented valid Torrens titles, the land was already registered, and the trial court was divested of jurisdiction to hear WIDORA’s original application. The case was remanded with instructions for the trial court to dismiss WIDORA’s application for lack of jurisdiction.