Professional Documents
Culture Documents
Issue:
Whether or not the petitioners can question the validity of the title of the respondents over the property in dispute?
Ruling and Rationale:
No. The court held that a land registration is an in rem proceeding which involves a constructive notice against all persons
including the state which is effective through the publication of the application for land registration. The court held that when more
than one certificate of title is issued over the land, the person holding the prior certificate of title is entitled to a better right against the
person who relies on the subsequent certificate. This rule refers to the date of the certificate of title and not on the date of filing
the application for registration of title. In land registration proceedings, all interested parties are obliged to take care of their interests
and to zealously pursue their objective of registration on account of the rule that whoever first acquires title to a piece of land shall
prevail. The publication made with respect to the application of the respondents served as a constructive notice against the whole
world thus the court upheld the validity of their title and its indefeasibility against collateral attack from the petitioners. The record
does not show why petitioners did not have actual knowledge of the registration proceedings instituted by private respondents.
However, the lack of such knowledge in fact raises a doubt as to the veracity of their claim that they were in possession of the land. If
indeed they possessed the property, even if through an administrator, as diligent owners, the threat to their ownership could not have
escaped them considering that the property is in a rural community where news travels fast.
Granting that the petitioners did not have actual knowledge about the respondents application to the land, they waited for 7
more years after knowing that the property was already registered in the name of the respondents to demand for the execution of
judgment and cancellation of the respondents title. Therefore the SC finds them guilty of latches. Petitioners petition was denied.
Doctrine
In land registration proceedings, an in rem proceeding, all interested parties are obliged to take care of their interest and to
zealously pursue their objective of registration on account of the rule that whoever first acquires title to a piece of land shall prevail.
Where more than one certificate of title is issued over the land, the person holding a prior certificate is entitled to the land, as against a
person who relies on a subsequent certificate. This rule refers to the date of the certificate of title, not the date of filing.
The doctrine of stale demands or laches is based on grounds of public policy which requires, for the peace of society, the
discouragement of stale claims and is principally a question of the inequity or unfairness of permitting a right or claim to be enforced
or asserted. Land registration proceedings entails a race against time and non-observance of time constraints imposed by law exposes
an applicant to the loss of registration rights if not to the deleterious effects of the application of the doctrine of laches. An applicant
for registration has but a one-year period from the issuance of the decree of registration in favor of another applicant, within which to
question the validity of the certificate of title issued pursuant to such decree. Once the one-year period has lapsed, the title to the land
becomes indefeasible