### Facts:
The case stems from a long-standing land dispute between Nicasio Macutay (petitioner) and Sosima Samoy, Alfredo Granil, Rene Acorda, Noblito Samoy, and Sibirino Roque (respondents). This occurs over a parcel of land located in Barangay Liwanag, Tumauini, Isabela. Nicasio holds Original Certificate of Title (OCT) No. P-20478 for 12 hectares, tracing ownership to his stepfather, Fortunato Manuud. Respondents possess 3 hectares of this land, claiming tenancy under Urbana Casasola, the holder of OCT No. P-4319 and later Transfer Certificate of Title (TCT) No. T-8058 (issued to Eugenio Vehemente, Urbana’s heir).
1. **1946-1955:** Urbana filed and later received a homestead patent approved by the Bureau of Lands, leading to OCT No. P-4319 issuance.
2. **1955-1959:** Fortunato Manuud protested Urbana’s patent issuance. His appeals were dismissed for lack of prima facie evidence of fraud.
3. **1960:** Fortunato’s heirs filed a certiorari petition with the Court of First Instance (CFI), leading to a favorable decision but did not pursue the protest.
4. **1972:** Nicasio secured OCT No. P-20478 without further legal pursuit of Fortunato’s claims.
5. **2007:** Nicasio filed an “Accion Reinvindicatoria with Damages,” which was dismissed by the RTC for lack of possession evidence. On appeal, the CA also denied relief based on laches.
### Issues:
1. **Whether the validity of Nicasio’s Torrens title can be assailed in this case.**
2. **Whether Nicasio is entitled to recover possession of the Disputed Portion.**
### Court’s Decision:
**Issue 1: Validity of Nicasio’s Torrens Title**
– **Ruling:** The Supreme Court held that there was no collateral attack on Nicasio’s title. In the context of an accion publiciana, which centers around possession rights rather than ownership disputes, any incidental discussions regarding ownership remain provisional.
**Issue 2: Right to Recover Possession**
– **Ruling:** Nicasio’s claim was denied based on the principle of laches. The court ruled that his long delay (34 years) in asserting his rights barred his claim. Furthermore, respondents’ possession was deemed to derive from Urbana’s earlier registered title which took precedence over Nicasio’s later-acquired title.
### Doctrine:
1. **Accion Publiciana vs. Accion Reinvindicatoria:** Accion publiciana is an action to recover the better right of possession and may involve preliminary consideration of ownership, but it does not permanently determine title validity.
2. **Priority of Registration:** As per Legarda vs. Saleeby, in cases of overlapping registrations, the earlier title (Urbana’s OCT No. P-4319 dated February 7, 1955) prevails over the later one (Nicasio’s OCT No. P-20478 dated 1972).
3. **No Collateral Attack on Torrens Title:** Provisions under PD 1529 bar any alteration, modification, or cancellation of a title except through direct proceedings.
### Class Notes:
– **Accion Publiciana:** Suit for recovery of possession beyond one year since dispossession.
– **Critical Statute: Article 428, Civil Code – Right of Action for Owners**
– **Practical for Land Disputes**: Ownership determination is provisional, not impacting title permanence.
– **Laches:** Legal concept barring claims due to undue delay in pursuit.
– **Case Application:** Macutay’s delay (34 years) in asserting his rights led to the application of laches.
– **Property Registration Decree (PD 1529):** Protects title integrity from collateral attacks.
– **Key Provision: Section 48**
– **Priority of Registration Doctrine:** Earlier registration prevails in title conflicts.
### Historical Background:
The case involves a classic property dispute rooted in post-World War II land occupancy and ownership claims in rural Philippines. The legal wrangle draws on the homesteading laws and the Torrens system, reflecting the challenges of land titling and the enduring legacy of colonial-era property systems in the Philippines. The dispute has persisted through various legal fora, demonstrating systemic inefficiencies and the personal impact of legal uncertainties on land tenure.
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