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Spouses Alcantra V Spouses Belen

This case involves a dispute over ownership of Lot No. 16932. [1] Petitioners presented a certificate of title (TCT No. T-36252) as proof of their ownership, while respondents countered with tax declarations and deeds of sale. [2] The Supreme Court ruled that the certificate of title is an absolute and indefeasible evidence of ownership that cannot be defeated by tax declarations or deeds of sale. [3] The Court also found that the Court of Appeals erred in declaring void the free patent of the petitioner's predecessor and ruling that she was not a lawful heir, as such declarations must be made in a special proceeding, not an ordinary action.

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80 views2 pages

Spouses Alcantra V Spouses Belen

This case involves a dispute over ownership of Lot No. 16932. [1] Petitioners presented a certificate of title (TCT No. T-36252) as proof of their ownership, while respondents countered with tax declarations and deeds of sale. [2] The Supreme Court ruled that the certificate of title is an absolute and indefeasible evidence of ownership that cannot be defeated by tax declarations or deeds of sale. [3] The Court also found that the Court of Appeals erred in declaring void the free patent of the petitioner's predecessor and ruling that she was not a lawful heir, as such declarations must be made in a special proceeding, not an ordinary action.

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fcnrrs
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© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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SPOUSES ALCANTRA v. SPOUSES BELEN, ET AL.

G.R. No. 200204, 25 April 2017


First Division, Sereno

Indefeasibility of certificate of title

Petitioners filed a suit for quieting of title and reconveyance of


possession of Lot No. 16932 occupied by respondents. To prove their
claim, petitioners submitted TCT No. T-36252, tax declarations, and
sketch/special plan of Lot No. 16932. Respondents countered that they
bought the property; they presented tax declarations and a
sketch/special plan. The RTC ruled for petitioners. Upon appeal, the CA
found for respondents; it also declared as void the free patent of
petitioner’s predecessor and declared her as not a legal heir.

A. May a certificate of title be sufficiently defeated by tax


declarations and deeds of sale?

No. The certificate of title of petitioners is an absolute wad indefeasible


evidence of their ownership of the property. The irrelevant tax
declarations of respondents cannot defeat TCT No. T-36252 of
petitioners, as it is binding and conclusive upon the whole world.

As against an array of proofs consisting of tax declarations and/or tax


receipts which are not conclusive evidence of ownership nor proof of the
area covered therein, an original certificate of title indicates true and
legal ownership by the registered owners over the disputed premises.
B. Did the CA err in declaring void the free patent of petitioner’s
predecessor and ruling that she is not a lawful heir?

Yes. The CA failed to cite any specific exhibit on record showing that
petitioner’s predecessor did not possess the land when she applied for
the patent. Also, courts must refrain from making a declaration of
heirship in an ordinary action because matters relating to the rights of
filiation and heirship must be ventilated in a special proceeding
instituted precisely for the purpose of determining such rights.

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