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    Naval v. CA, GR 167412, Feb. 2, 2006, 483 SCRA 102

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    Gia Dimayuga
    This case involves a dispute over ownership of a parcel of land between the petitioner and respondents. The petitioner claimed she purchased the land in 1972 and was issued a certificate of title in 1975, while the respondents purchased portions of the same land from the original owner's grantee in the 1960s. The Court ruled that the respondents have superior right over the property, as registration and a certificate of title do not necessarily determine true ownership, and one cannot use a certificate of title to protect a usurper or commit fraud against the rightful owner.

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    Naval v. CA, GR 167412, Feb. 2, 2006, 483 SCRA 102

    Uploaded by

    Gia Dimayuga
    241 views1 page
    This case involves a dispute over ownership of a parcel of land between the petitioner and respondents. The petitioner claimed she purchased the land in 1972 and was issued a certificate of title in 1975, while the respondents purchased portions of the same land from the original owner's grantee in the 1960s. The Court ruled that the respondents have superior right over the property, as registration and a certificate of title do not necessarily determine true ownership, and one cannot use a certificate of title to protect a usurper or commit fraud against the rightful owner.

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    243. Naval v. CA, GR 167412, Feb. 2, 2006, 483 SCRA 102

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    This case involves a dispute over ownership of a parcel of land between the petitioner and respondents. The petitioner claimed she purchased the land in 1972 and was issued a certificate of title in 1975, while the respondents purchased portions of the same land from the original owner's grantee in the 1960s. The Court ruled that the respondents have superior right over the property, as registration and a certificate of title do not necessarily determine true ownership, and one cannot use a certificate of title to protect a usurper or commit fraud against the rightful owner.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    241 views1 page

    Naval v. CA, GR 167412, Feb. 2, 2006, 483 SCRA 102

    Uploaded by

    Gia Dimayuga
    This case involves a dispute over ownership of a parcel of land between the petitioner and respondents. The petitioner claimed she purchased the land in 1972 and was issued a certificate of title in 1975, while the respondents purchased portions of the same land from the original owner's grantee in the 1960s. The Court ruled that the respondents have superior right over the property, as registration and a certificate of title do not necessarily determine true ownership, and one cannot use a certificate of title to protect a usurper or commit fraud against the rightful owner.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    of 1

    243. Naval v. CA, GR 167412, Feb.

    2, 2006, 483 SCRA 102

    FACTS

    On December 2, 1969, Ildefonso A. Naval sold a parcel of land to Gregorio B. Galarosa.


    The sale was recorded in the Registry of Property of the Registry of Deeds of
    Camarines Sur on December 3, 1969 pursuant to Act No. 3344, the law governing
    registrations of all instruments on unregistered lands. Subsequently, Gregorio sold
    portions of the land to respondent-buyers who occupied the portion they bought, built
    improvements thereon, and paid the taxes due thereto.

    The controversy arose when petitioner Juanita Naval, the great granddaughter of
    Ildefonso, was issued on April 1, 1975 by the Register of Deeds of Camarines Sur an
    Original Certificate of Title (OCT) No. RP-5386 (29791), covering 733 sq. m. of the
    subject land. She claimed that she bought the subject land from Ildefonso in 1972.
    Petitioner filed a complaint for recovery of possession against respondent-buyers, which
    was docketed as Civil Case No. 306.

    ISSUE

    Whether or not respondents have superior right over the property?

    RULING

    Yes. Even if petitioner argues that she purchased and registered the subject land in
    good faith and without knowledge of any adverse claim thereto, respondents still have
    superior right over the disputed property. True, a certificate of title, once registered,
    should not thereafter be impugned, altered, changed, modified, enlarged or diminished
    except in a direct proceeding permitted by law. Moreover, Section 32 of Presidential
    Decree No. 1529 provides that "upon the expiration of said period of one year, the
    decree of registration and the certificate of title shall become incontrovertible."

    However, it does not deprive an aggrieved party of a remedy in law. What cannot be
    collaterally attacked is the certificate of title and not the title or ownership which is
    represented by such certificate. Ownership is different from a certificate of title. The fact
    that petitioner was able to secure a title in her name did not operate to vest ownership
    upon her of the subject land. Registration of a piece of land under the Torrens System
    does not create or vest title, because it is not a mode of acquiring ownership. A
    certificate of title is merely an evidence of ownership or title over the particular property
    described therein. It cannot be used to protect a usurper from the true owner; nor can it
    be used as a shield for the commission of fraud; neither does it permit one to enrich
    himself at the expense of others. Its issuance in favor of a particular person does not
    foreclose the possibility that the real property may be co-owned with persons not named
    in the certificate, or that it may be held in trust for another person by the registered
    owner.

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