FABIAN GARCIA, ANATALIA GARCIA AND BENJAMINA GARCIA., PETITIONERS, VS. HON. ELOY B. BELLO, JUDGE OF THE COURT OF FIRST INSTANCE OF PANGASINAN AND PEDRO DE GUZMAN, RESPONDENTS.

Garcia versus Bello

The Case

This is a petition for certiorari and prohibition filed with the Supreme Court by Fabian Garcia, Anatalia Garcia, and Benjamina Garcia against Judge Eloy Bello of the Court of First Instance of Pangasinan and Pedro de Guzman. The petitioners ask the Court to restrain the respondent judge from enforcing his order directing the issuance of a writ of possession in favor of de Guzman over a tract of land in San Carlos, Pangasinan, and requiring the petitioners to remove their houses from that land. The case matters because it teaches the finality of judgments, the binding effect of a land registration decree against the whole world, and the rule that a question of ownership already settled by final judgment cannot be reopened through a fresh petition.

Procedural History

The dispute began in a land registration proceeding before the Court of First Instance of Pangasinan, where de Guzman applied to register the land in his name. Judgment was rendered in his favor and a certificate of title was issued. The petitioners later sued de Guzman in the same court for reconveyance, but the complaint was dismissed, and the Supreme Court affirmed the dismissal. When de Guzman later moved in the land registration case for a writ of possession, the respondent judge granted it, and the Supreme Court, in an earlier decision promulgated on April 30, 1965, upheld the judge's authority to issue the writ. The petitioners' motion for reconsideration of that earlier decision was denied on June 2, 1965. The respondent judge then issued the order of May 29, 1965 giving the petitioners twenty days to remove their houses from the land. The petitioners filed the present petition for certiorari and prohibition, which the Supreme Court initially dismissed for insufficient allegations and lack of supporting papers, but later reconsidered and gave due course. A second petition for prohibition with a prayer for a preliminary injunction was filed by the same petitioners against the same judge, and the Court required the judge to answer. The two petitions were resolved together.

Facts

On October 18, 1918, Pedro de Guzman instituted a land registration proceeding for a tract of land in San Carlos, Pangasinan. Judgment was rendered in his favor on January 30, 1923, and Original Certificate of Title Number 25381 was issued in his name on July 18, 1923.

In March 1959, the petitioners, together with Vicente Garcia, sued de Guzman for reconveyance, claiming that the registration decree had been obtained through fraud from Juan Garcia, the petitioners' father. The trial court dismissed the complaint, and the Supreme Court affirmed the dismissal, holding that the registration decree barred the claim. When de Guzman later moved for a writ of possession in the land registration case, the respondent judge granted it, and the Supreme Court upheld that order in its decision of April 30, 1965.

The petitioners then opposed the writ on a new theory. They claimed that of the eighty-four hectares covered by the registration, only sixty-seven hectares belonged to de Guzman, who had allegedly leased that portion to two tenants, and that the remaining seventeen hectares had been sold by de Guzman to Juan Garcia, as shown by two deeds of sale supposedly executed in 1916 and 1938. On this basis they asked the respondent judge to reconsider his order, and when he refused, they brought these petitions to the Supreme Court.

Issues

• Whether or not the respondent judge abused his discretion in issuing the writ of possession in favor of de Guzman.
• Whether or not the petitioners' new claim over the seventeen-hectare portion, based on the two deeds of sale, can defeat the writ of possession.
• Whether or not the question of ownership of the land has already been finally determined by prior judgment.

Applicable Provisions

The decision does not quote a specific statutory provision, but it applies the settled rule on land registration proceedings. The Court states the governing principle in these words:

A land registration case is a proceeding in rem, and accordingly, the decision therein rendered is binding upon the whole world.

This principle means that the decree of registration in favor of de Guzman binds the petitioners and everyone else, whether or not they were parties to the registration case.

The Court also applies the rule on prescription, stating:

Even if the parcel of land were not registered in the name of the appellee under the Torrens system he would have acquired title to it by prescription no matter how the possession thereof had originated or begun, which precludes an action for its recovery on the ground of fraud.

This means that de Guzman's long possession and registered title bar any belated action to recover the land on the ground of fraud.

Ruling

On the first issue, the Court held that the respondent judge did not abuse his discretion. The very same issue had already been resolved in the earlier decision of April 30, 1965, which upheld the judge's authority to issue the writ of possession. The Court saw no reason to depart from that ruling.

On the second issue, the Court held that the two deeds of sale could not help the petitioners. If Juan Garcia had truly acquired the seventeen-hectare portion in 1916, he should have opposed de Guzman's petition for registration filed in 1918. He never sought annulment of the registration, never brought an action to enforce his alleged rights from 1918 until his death in 1950, and the petitioners themselves never invoked these documents in the earlier cases. The Court said these two documents cannot avail the petitioners any.

On the third issue, the Court held that the question of ownership of the entire eighty-four hectares had been finally determined in the prior cases, which involved the same parties and the same subject-matter. The Court declared that the decree of land registration in favor of de Guzman bars the claim of the petitioners over the same land, including the seventeen-hectare portion. The Court also noted that even without the Torrens title, de Guzman had acquired the land by prescription.

Doctrine

A land registration case is a proceeding in rem, and the decision rendered therein is binding upon the whole world. A decree of registration in favor of the applicant bars any later claim of ownership over the registered land, including a claim based on documents that the claimant or his predecessor could have presented in the registration proceedings but did not. A question of ownership already settled by final judgment cannot be reopened in a subsequent petition involving the same parties and the same subject-matter. A party who sleeps on his rights for decades cannot invoke them against a registered owner who has held title and possession for that length of time.

Disposition

The Supreme Court dismissed the petition for being patently unmeritorious, with double costs against the petitioners.

Remember This

Remember the line that a land registration case is a proceeding in rem, so the decision binds the whole world. Examiners use this case to test the finality of registration decrees and the rule that stale claims over registered land cannot be revived through certiorari and prohibition.