By Benjamin B. Pulta
02/14/2012 [ tribune.net.ph ]
A ruling by the Supreme Court (SC) has upheld the ruling of the Court of Appeals (CA) in favor of the San Miguel Corporation (SMC) over the ownership of more than 8,000 square meters in Valenzuela known as the Malinta Estate.
In its decision by Associate Justice Mariano del Castillo, the high court’s First Division upheld the CA decision of April 21, 2006 decision on the case.Chief Justice Renato Corona and Associate Justices Teresita Leonardo-de Castro, Martin Villarama, Jr. concurred.
The CA had affirmed the trial court’s judgment, which dismissed a complaint for the nullification of the title of SMC predecessor-in-interest, Ramie Textile , Inc., over Lot 1131 of the Malinta Estate and granted Ramitex’ prayer for the cancellation of petitioner Leoncio Oliveros’ title over the subject property.
This case involves a parcel of land known as Lot 1131 of the Malinta Estate located in Barrio Bagbaguin of Valenzuela, Metro Manila.
Ramitex bought the subject property from co-owners Tomas Soriano and Concepcion Lozada in 1957. On the basis of such sale, the Register of Deeds of Bulacan cancelled the vendors’ Transfer Certificate of Title (TCT) No. 29334 and issued TCT No. T-18460 on March 6, 1957 in favor of Ramitex. Lot 1131 is just one of the 17 lots owned by Ramitex within the Malinta Estate.
In 1986, Ramitex consolidated and subdivided its 17 lots within the Malinta Estate into six lots only.
Lot 1131, which contains 8,950 square meters, was consolidated with portions of Lots 1127-A and 1128-B to become consolidated Lot No. 4.
The consolidated area of Lot 4 is 16,958 square meters. By virtue of this consolidation, the Register of Deeds of Caloocan City cancelled Ramitex’ individual title to Lot 1131 and issued a new title, for the consolidated Lot 4.
Troubles began for Ramitex on Feb. 22, 1989, when Oliveros filed a petition in Branch 172 of the Regional Trial Court of Valenzuela for the reconstitution of TCT No. T-17186, his alleged title over Lot 1131 of the Malinta Estate . He claimed that the original copy was destroyed in the fire that gutted the office of the Bulacan RD on March 7, 1987.
Ramitex filed its opposition to Oliveros’ petition asserting that TCT No. T-17186 never existed in the records of the Bulacan RD and cannot therefore be reconstituted.
The State, through the provincial prosecutor, also opposed on the basis that Oliveros’ TCT No. T-17186, which is embodied on a judicial form with serial number, does not come from official sources.
The State submitted a certification from the Land Registration Authority (LRA) that its Property Section issued the form with Serial No. 124604 to the Register of Deeds of Davao City (Davao RD), and not to the Bulacan RD, as claimed in Oliveros’ alleged title.
In light of Ramitex’ opposition and ownership claims over Lot 1131, Oliveros filed a complaint for the declaration of nullity of Ramitex’ title over Lot 1131 on Nov. 16, 1990.
This complaint was docketed as Civil Case No. 3232-V-89 and raffled to Branch 172 of the Valenzuela RTC. Oliveros claimed that he bought the subject property sometime in Nov. 1956 from the spouses Domingo de Leon and Modesta Molina, and pursuant to such sale, the Bulacan RD issued TCT No. T-17186 in his favor on Nov. 14, 1956.
He was joined in the suit by his alleged overseers to Lot 1131, petitioners Moises and Felix dela Cruz, who were judicially ejected by Ramitex from Lot 1127 two years before.
Oliveros and his co-petitioners alleged that Ramitex did not own Lot 1131 and that its individual title to Lot 1131, TCT No. 18460, was fake and was used by Ramitex to consolidate Lot 1131 with its other properties in the Malinta Estate.
They further claimed that the resulting consolidated Lot 4 is not actually a consolidation of several lots but only contains Lot 1131, which belongs to Oliveros. Thus, they asked for the nullification as well of Ramitex’ title to consolidated Lot 4, insofar as it unlawfully included Lot 1131.
Given the prejudicial nature of the nullity case on the reconstitution case, the latter was held in abeyance until the resolution of the former.
Ramitex answered that its title over Lot 1131 is valid and claimed continuous possession and ownership of the subject property. It prayed for the dismissal of petitioners’ complaint
against it for lack of merit.
Ramitex counterclaimed that it is Oliveros’ title, TCT No. T-17186, that should be cancelled for being spurious and non-existent.
SMC substituted Ramitex as party-defendant after buying Ramitex’ interests over the subject property presented officials from various government offices to prove that Oliveros’ purported title to Lot 1131 does not actually exist in the official records.
The trial court found overwhelming evidence supporting SMC’s claim as to the validity of its title to the subject property.The title from which SMC’s predecessor-in-interest Ramitex derived its own title, was in the name of Ramitex’ vendors Soriano and Lozada, and was still in existence in the Bulacan RD.
After reviewing the factual findings of the trial court, the CA agreed that there is no evidence that Oliveros’ title came from official sources and that on the other hand, SMC adequately established the existence and validity of its title .
“Given that these titles exist in official sources, they are indefeasible unless and until credible evidence is presented to obtain their annulment on grounds of fraud.” the SC said.
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