The Supreme Court ruled that a certificate of title issued under the Torrens system cannot be collaterally attacked in a case primarily seeking a different remedy. This means landowners with Torrens titles have stronger protection against indirect challenges to their ownership. The ruling reinforces the indefeasibility of land titles, ensuring stability and predictability in property rights and transactions.

Safeguarding Land Ownership: Can a Deed of Sale Undermine a Torrens Title?

In 1979, Antonio Garcia purchased a 29-hectare parcel of land in Davao Oriental. Years later, he divided the land among his children and grandchildren through deeds of transfer. The family then applied for and received land titles under the DENR’s Handog Titulo program, registering their certificates of title. Subsequently, a group of individuals holding Certificates of Land Ownership Award (CLOA) filed a petition to annul the original deed of sale, arguing it violated the Comprehensive Agrarian Reform Law. This legal battle questioned whether a deed of sale could be invalidated in a way that would undermine the validity of Torrens titles derived from that sale, bringing into sharp focus the legal principle against collateral attacks on land titles.

The core issue revolves around the prohibition against collateral attacks on Torrens certificates of title, as enshrined in Section 43 of Presidential Decree No. 1529. This law, also known as the Property Registration Decree, aims to protect the integrity and indefeasibility of land titles. A direct attack is defined as an action specifically intended to annul or set aside a judgment that led to the issuance of a registration decree. Conversely, a collateral attack occurs when the validity of a judgment is questioned incidentally in a different action. The Supreme Court has consistently upheld the sanctity of the Torrens system, designed to quiet titles and prevent endless litigation over land ownership.

The respondents, holders of CLOAs, sought to nullify the 1979 deed of sale between Antonio Garcia and the original landowner, arguing it violated Section 6 of Republic Act No. 6657, the Comprehensive Agrarian Reform Law of 1988. This provision states:

SECTION 6. Retention Limits. — [x x x]

x x x [x]

Upon the effectivity of this Act, any sale, disposition, lease, management, contract or transfer of possession of private lands executed by the original landowner in violation of this Act shall be null and void: Provided, however, That those executed prior to this Act shall be valid only when registered with the Register of Deeds within a period of three (3) months after the effectivity of this Act. Thereafter, all Registers of Deeds shall inform the Department of Agrarian Reform (DAR) within thirty (30) days of any transaction involving agricultural lands in excess of five (5) hectares.

The respondents contended that because the 1979 deed of sale was not registered within three months of RA 6657’s effectivity, it was void, rendering all subsequent transfers and titles invalid. This argument, however, was seen as an attempt to indirectly attack the validity of the petitioners’ Torrens titles.

The Provincial Adjudicator initially dismissed the respondents’ petition, recognizing it as an impermissible collateral attack. The DARAB, however, reversed this decision, declaring the deed of sale and subsequent transfers void. The Court of Appeals affirmed the DARAB’s ruling, leading to the Supreme Court appeal. The Supreme Court emphasized that the respondents’ action before the Provincial Adjudicator was indeed a collateral attack on the petitioners’ certificates of title. The court cited Vicente v. Avera, highlighting that questioning the validity of a deed of sale that underpins a registered title constitutes a prohibited collateral attack.

It was erroneous for respondents to assail the deed of sale executed on October 1, 1987 in favor of petitioners, because this constitutes a collateral attack on petitioners’ TCT. Section 48 of P.D. No. 1529 prohibits a collateral attack on a Torrens title. This Court has held that a petition which, in effect, questioned the validity of a deed of sale for registered land constitutes a collateral attack on a certificate of title. In the case at bar, respondents’ allegation, that the deed of sale executed on October 1, 1987 in favor of petitioners does not exist, clearly constitutes a collateral attack on a certificate of title. The allegation of the inexistence of the deed of sale in effect attacks the validity of the TCT issued in the petitioners’ names.

The Supreme Court found that by giving due course to the appeal, the DARAB gravely abused its discretion, and the CA erred in affirming this decision. The Court underscored that an attack on a deed of sale is effectively an attack on the certificates of title derived from it. This decision reinforces the principle that Torrens titles can only be challenged directly in a specific action designed for that purpose.

Moreover, the Court noted that the DARAB overstepped its authority by declaring the certificates of title void based on a collateral attack. Certificates of title that are derived from the DENR’s grant of patents, not from CARP-related awards, fall outside the DARAB’s jurisdiction. By effectively invalidating these titles, the DARAB exceeded its legal mandate.

Recognizing this, the respondents themselves initiated a direct complaint for cancellation of the petitioners’ Torrens certificates of title before the RTC of Lupon, Davao Oriental. The Supreme Court acknowledged this as the more appropriate forum for resolving disputes regarding the validity of land titles.

FAQs

What is a Torrens title?	A Torrens title is a certificate of ownership issued under the Torrens system, a land registration system designed to ensure the indefeasibility of land titles. It provides greater security and simplifies land transactions.
What is a collateral attack on a title?	A collateral attack is an attempt to challenge the validity of a land title indirectly, in a legal action that has a different primary purpose. This is generally prohibited under the Torrens system to protect the stability of land ownership.
What is a direct attack on a title?	A direct attack is a legal action specifically initiated to challenge the validity of a land title. This involves a formal proceeding where the main objective is to annul or set aside the title.
What is the Comprehensive Agrarian Reform Law (CARL)?	The Comprehensive Agrarian Reform Law (CARL), or RA 6657, is a Philippine law that aims to redistribute agricultural lands to landless farmers. It includes provisions on land acquisition, distribution, and compensation.
What is the role of the DARAB in land disputes?	The Department of Agrarian Reform Adjudication Board (DARAB) is responsible for resolving agrarian disputes. However, its jurisdiction is limited to matters related to agrarian reform and does not extend to all land disputes.
Why was the DARAB’s decision overturned?	The DARAB’s decision was overturned because it allowed a collateral attack on Torrens titles and exceeded its jurisdiction by effectively invalidating certificates of title derived from DENR patents.
What is the significance of registering a deed of sale?	Registering a deed of sale provides public notice of the transaction and protects the buyer’s rights against third parties. Under RA 6657, failure to register a sale within a specified period can render the sale void.
What should landowners do to protect their titles?	Landowners should ensure their titles are properly registered under the Torrens system and promptly address any challenges to their ownership through appropriate legal channels. Seeking legal advice is crucial in navigating complex land disputes.

This Supreme Court decision underscores the importance of upholding the integrity of the Torrens system and safeguarding the rights of registered landowners. It serves as a reminder that challenges to land titles must be pursued through direct actions, respecting the established legal framework designed to ensure stability and predictability in property ownership. This case emphasizes the critical role of direct legal challenges in land disputes, ensuring fairness and due process for all parties involved.

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: ANTONIO GARCIA, ET AL. VS. FELIPE NERI ESCLITO, ET AL., G.R. No. 207210, March 21, 2022