SPS. ALCANTARA v. SPS. BELEN

SPOUSES ELVIRA ALCANTARA AND EDWIN ALCANTARA, Petitioners, - versus - SPOUSES FLORANTE BELEN AND ZENAIDA ANANIAS, THE PROVINCIAL ENVIRONMENT AND NATURAL RESOURCES OFFICER, DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES, STA. CRUZ, LAGUNA, and THE CITY ASSESSOR OF SAN PABLO CITY, Respondents.

G.R. No. 200204

April 25, 2017

FACTS: 

In 2005, Spouses Alcantara filed before the RTC a Complaint against Spouses Belen for the quieting of title, reconveyance of possession, and accounting of harvest with damages. Petitioners argued that their neighbors, respondents herein, had extended the latter's possession up to the land titled to Spouses Alcantara, and usurped the harvests therefrom.

Spouses Alcantara claimed that they were the registered owners of Lot No. 16932, 3,887-square-meter parcel of land planted with trees. Elvira Alcantara traced her ownership of the property to her inheritance from her mother, Asuncion Alimon.

In addition to the certificate of title, Spouses Alcantara submitted as evidence the Tax Declarations of the property registered to them and their predecessors-in-interest, receipts of their payments for real property taxes, and a Sketch/Special Plan of Lot No. 16932 prepared by Geodetic Engineer Augusto C. Rivera.

On the strength of a sales agreement called Kasulatan ng Bilihang Tuluyan ng Lupa,  respondents countered Spouses Alcantara's claims over the property. Spouses Belen alleged that they bought the property from its prior owners. Even though respondents did not have any certificate of title over the property, they supported their claim of ownership with various Tax Declarations under the name of their predecessors-in-interest. Spouses Belen also submitted a Sketch/Special Plan of Lot No. 16932 prepared by Geodetic Engineer Hector C. Santos.

Furthermore, Spouses Belen attacked the OCT of Asuncion Alimon. They claimed that fraud attended the issuance of a Free Patent to her, considering that the Belens had occupied the property ever since. According to respondents, they already protested her title still pending before the Community Environment and Natural Resources Office (CENRO) of the Department of Environment and Natural Resources (DENR).

ISSUE: 

Whether or not a certificate of title may be sufficiently defeated by tax declarations and deeds of sale.

HELD: 

No. Based on established jurisprudence, we rule that the certificate of title of petitioners is an absolute and indefeasible evidence of their ownership of the property. The irrelevant Tax Declarations of Spouses Belen cannot defeat TCT No. T-36252 of Spouses Alcantara, as it is binding and conclusive upon the whole world. Cureg v. Intermediate Appellate Court explains:

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. Petitioners' OCT No. P-19093 should be accorded greater weight as against the tax declarations xx x offered by private respondents in support of their claim xx x.