HEIRS OF VENCILAO V. CA

Category: Property, Ownership and Its Modifications

HEIRS OF VENCILAO V. CA

One may not acquire property by prescription when that property is titled to another under the Torrens System. It does not even matter whether occupation by the adverse claimant was open, notorious and continuous. As long as the TCT is in someone else’s name, the property belongs to person who holds the TCT

FACTS:

On Feb 12, 1990, the heirs of Vencilao filed a complaint to quiet the title and recover a piece of land against spouses Gepalgo.

Said heirs asserted that they acquired the land from their father who was in open, peaceful and notorious enjoyment of the same. They presented tax declarations to prove said ownership
On the other hand, the Gepalgo spouses denied the claim and for proof as registered owners, presented TCT No. 16042 which they acquired on public auction from the PNB.

RTC ruled in favor of Vencilao because the latter had been in possession, cultivation and enjoyment for more than 30 years- long before a title was ever issued to the Gepalgos.

Upon appeal, the CA reversed and awared the property to Gepalgos because the latter were buyers in good faith and holders in due course. Furthermore, they held a Torrens Title. That was the gold standard of ownership for registered land.

Naturally, the heirs of Vencilao trooped to the Supreme Court.

ISSUE:

Whether or not the Gepalgos had better right to the land.

HELD:

No.The RTC erroneously found for the petitioners. True, the Vencilaos enjoyed the property for more than 30 years. However, prescription does not run against registered land. No one may acquire by prescription or adverse possession land that is titled and registered even if occupation is adverse, open and notorious. A Certificate of Title is absolute and unbeatable evidence of ownership in favor of the person whose name appears upon it. It binds the whole world.