The Supreme Court’s decision in Go Ramos-Yeo v. Spouses Chua underscores the principle that land registration decrees become incontrovertible after one year, protecting landowners from indirect attacks seeking to alter their titles outside proper land registration proceedings. The Court reiterated that an accion reinvindicatoria cannot be used to circumvent the indefeasibility of a Torrens title, especially when the true intent is to reopen or amend a final decree of registration. This ruling reinforces the stability of land titles and clarifies jurisdictional boundaries between ordinary civil courts and land registration courts.

Accion Reinvindicatoria or Collateral Attack? Unraveling a Land Dispute in Tagaytay

The case revolves around a dispute between Marilyn L. Go Ramos-Yeo, Laurence L. Go, and Montgomery L. Go (the Gos), and Spouses Richard O. Chua and Polly S. Chua concerning land boundaries in Tagaytay City. The Spouses Chua filed a complaint for accion reinvindicatoria, seeking to recover possession and ownership of a portion of land they claimed was encroached upon by the Gos and Multi-Realty Development Corporation. The central legal question was whether the Spouses Chua’s action was a genuine case of recovering property, or an impermissible collateral attack on the Gos’ and Multi-Realty’s land titles which would require a land registration court’s jurisdiction.

The Supreme Court (SC) determined that the Regional Trial Court (RTC) did not properly acquire jurisdiction over the persons of the Gos due to an invalid substituted service of summons. The decision underscored that for substituted service to be valid, there must be evidence of the serving officer’s diligent attempts to personally serve the summons. In this case, the sheriff failed to demonstrate that he made serious efforts to personally serve the summons on the Gos before resorting to substituted service through a certain Patricio Alampay. As such, the court emphasized the necessity of strict compliance with the rules on substituted service to ensure due process.

Building on this point, the SC also found that the RTC lacked jurisdiction over the subject matter of the case. The Court emphasized that the action filed by the Spouses Chua, while purportedly an accion reinvindicatoria, was in reality an attempt to indirectly attack the validity of the Gos’ and Multi-Realty’s certificates of title. The Court cited Sections 32 and 108 of Presidential Decree No. (PD) 1529, also known as the Property Registration Decree, as the basis for its ruling. Section 32 provides for the incontrovertibility of a title after one year from the entry of the decree of registration:

Section 32. Upon the expiration of the time to appeal from the order or decree of registration as provided in this Decree, and in the absence of any appeal or motion, the decree of registration and the certificate of title issued shall become incontrovertible. Any person aggrieved by such decree in any case may pursue his remedy by action for damages against the applicant or any other persons responsible for the fraud in obtaining the decree. However, such action shall not bar the innocent purchaser for value from the land.

Section 108 outlines the procedure for altering certificates of title, which must be conducted through a direct proceeding in a land registration court. The Court held that the Spouses Chua’s attempt to alter the boundaries of the properties owned by the Gos and Multi-Realty through an ordinary civil action was a circumvention of this provision. The proper venue for such an action would be a court sitting as a land registration court, not an ordinary civil court.

The Court distinguished between a direct and a collateral attack on a certificate of title. A direct attack is a proceeding where the object is to annul or set aside such judgment, or enjoin its enforcement. A collateral attack, on the other hand, is an attempt to defeat the judgment in a manner not provided by law, such as in an action for recovery of property. The SC clarified that the Spouses Chua’s action constituted a collateral attack because it sought to alter the registered boundaries without directly challenging the validity of the land titles in a land registration proceeding. Since the titles issued to the Gos and Multi-Realty had become incontrovertible, any attempt to alter them outside of the proper land registration procedures was deemed improper.

The Court emphasized that the indefeasibility of a Torrens title is a cornerstone of the Torrens system, which aims to provide stability and security to land ownership. Permitting indirect attacks on land titles through ordinary civil actions would undermine this system and create uncertainty in property rights. Therefore, the SC reinforced the principle that once a decree of registration has been issued and the one-year period has lapsed, the title becomes conclusive and cannot be challenged except in a direct proceeding.

Moreover, the Court addressed the issue of laches raised by the Spouses Chua. Laches is the failure or neglect, for an unreasonable and unexplained length of time, to do that which, by exercising due diligence, could or should have been done earlier; it is negligence or omission to assert a right within a reasonable time, warranting a presumption that the party entitled to assert it either has abandoned it or declined to assert it. However, the Court held that laches could not be invoked against the Gos and Multi-Realty because the trial court lacked jurisdiction over their persons and the subject matter. A void judgment confers no rights and imposes no obligations; therefore, the defense of laches could not be applied to validate a void proceeding.

In summary, the Supreme Court’s decision underscores several critical principles in Philippine land law. First, it reinforces the importance of proper service of summons to ensure that a court acquires jurisdiction over a defendant. Second, it reiterates the indefeasibility of a Torrens title after one year from the decree of registration. Finally, it clarifies that an accion reinvindicatoria cannot be used as a tool to collaterally attack a land title, thereby preserving the integrity and stability of the Torrens system.

FAQs

What was the key issue in this case?	The key issue was whether the Spouses Chua’s complaint for accion reinvindicatoria was an impermissible collateral attack on the Gos’ and Multi-Realty’s land titles. The Court had to determine if the RTC had jurisdiction over the persons of the respondents and the subject matter of the case.
What is an accion reinvindicatoria?	An accion reinvindicatoria is an action to recover ownership of real property. It is filed by a person who has been deprived of their possession and seeks to be restored to their rightful ownership.
What is substituted service of summons?	Substituted service is a method of serving summons when personal service cannot be made after diligent efforts. It involves leaving copies of the summons at the defendant’s residence with a person of suitable age and discretion residing therein, or by leaving the copies at the defendant’s office or regular place of business with some competent person in charge.
Why was the substituted service deemed invalid in this case?	The substituted service was deemed invalid because the sheriff did not demonstrate that he made serious efforts to personally serve the summons to the Gos before resorting to substituted service. The sheriff also failed to ensure that the person receiving the summons was of suitable age and discretion.
What is a collateral attack on a land title?	A collateral attack is an attempt to defeat the judgment in a manner not provided by law, such as in an action for recovery of property where the validity of the title is questioned. This is in contrast to a direct attack, which is a proceeding where the object is to annul or set aside such judgment, or enjoin its enforcement.
What does it mean for a land title to be incontrovertible?	A land title becomes incontrovertible one year after the decree of registration has been issued. This means that the title is conclusive and cannot be challenged except in a direct proceeding for cancellation or amendment.
What is the significance of Presidential Decree No. 1529?	Presidential Decree No. 1529, also known as the Property Registration Decree, governs the registration of land in the Philippines. It provides the legal framework for the Torrens system, which aims to provide stability and security to land ownership.
What is the doctrine of laches?	Laches is the failure or neglect, for an unreasonable and unexplained length of time, to do that which, by exercising due diligence, could or should have been done earlier. It is negligence or omission to assert a right within a reasonable time, warranting a presumption that the party entitled to assert it either has abandoned it or declined to assert it.
Why was laches not applicable in this case?	Laches was not applicable because the trial court lacked jurisdiction over the persons of the Gos and the subject matter of the case. A void judgment confers no rights and imposes no obligations; therefore, the defense of laches could not be applied to validate a void proceeding.

In conclusion, the Supreme Court’s decision in Go Ramos-Yeo v. Spouses Chua provides important clarification on the requirements for valid service of summons, the indefeasibility of Torrens titles, and the distinction between direct and collateral attacks on land titles. This case serves as a reminder of the importance of adhering to the proper legal procedures in land disputes to ensure the stability and security of property rights in the Philippines.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Marilyn L. Go Ramos-Yeo, et al. vs. Spouses Richard O. Chua, et al., G.R. No. 236075, April 18, 2022