RITA S. MAYORMITA, PLAINTIFF-APPELLANT, VS. EQUITABLE PCI BANK, DEFENDANT-APPELLEE.

Mayormita versus Equitable PCI Bank

The Case

This is a case about two Torrens titles covering one parcel of land. Rita Mayormita sued Equitable PCI Bank to quiet title and to cancel the bank's certificate of title, claiming that her own title, issued in 1961, was the genuine one and that the bank's title was spurious. The bank answered that its title was valid and that it was a transferee in good faith. The case matters because it shows how a court resolves a clash of titles: the plaintiff must win on the strength of her own evidence, not on the weakness of the defendant's, and a title that cannot be traced to a decree of registration will not survive.

Procedural History

Rita Mayormita filed her complaint for quieting of title and cancellation of title with damages before Branch 11 of the Regional Trial Court of Malolos City, Bulacan. After trial, the court rendered a decision dismissing her complaint, annulling her certificate of title, ordering the Registry of Deeds to cancel it, ordering the amendment of the technical description in the bank's title, and awarding attorney's fees and costs to the bank. On the bank's motion for clarification and correction, the trial court issued an amended decision correcting the technical description, but the dispositive portion remained the same. Mayormita's motion for reconsideration was denied. She then appealed to the Supreme Court, and the Court affirmed the trial court.

Facts

The land, about 4,125 square meters in Libtong, Meycauayan, Bulacan, is covered by two titles. Mayormita holds a certificate of title issued in her name in February 1961. In 2004, while pursuing an ejectment case against the spouses Edgardo and Ma. Beatriz Sanchez, she discovered that the same land was also covered by a title issued in July 2004 in the name of Equitable PCI Bank.

The bank traced its title to a decree of registration, and its title passed through several owners: from the Datileses, to the Guisons, to PCI Leasing through foreclosure, to Mr. Sanchez, to Cherubin Laboratory, and finally to the bank through foreclosure of a real estate mortgage. Mayormita, for her part, relied on a certification from the Land Registration Authority and on the testimony of Engineer Porfirio Encisa to show that the bank's title referred to land in Tondo, Manila, and contained errors in the survey and lot numbers.

At trial, however, Engineer Encisa, Mayormita's own witness, testified that the certification had no relation to the subject property, and that the bank's title merely contained typographical errors in the lot number and survey number which did not invalidate it. He also testified that no application for registration and no decree existed for the plan behind Mayormita's title. The bank, on the other hand, presented the decree of registration on which its title was based.

Issues

• Whether or not the trial court erred in dismissing the complaint for quieting of title and cancellation of title with damages.
• Whether or not the trial court erred in annulling the certificate of title registered in Mayormita's name.

Applicable Provisions

The decision applies the rule on burden of proof and preponderance of evidence in civil cases, which the Court states as follows:

In civil cases, the burden of proof to be established by preponderance of evidence is on plaintiff who is asserting the affirmative of an issue.

This rule places the burden on Mayormita, as plaintiff, to prove her affirmative claim that her title was valid and the bank's title was spurious.

The Court also states the meaning of preponderance of evidence:

The concept of preponderance of evidence refers to evidence which is of greater weight, or more convincing than that which is offered in opposition to it; at bottom, it means probability of truth.

This standard is the measure by which the Court weighed the conflicting evidence of the parties.

Finally, the Court applies the rule that bad faith is not presumed:

Bad faith is not presumed and he who alleges the same has the onus of proving it.

This rule bears on Mayormita's failure to show that the bank acquired its title in bad faith.

Ruling

On the first issue, the Court held that the trial court did not err in dismissing the complaint. The burden of proof lay on Mayormita, and she had to rely on the strength of her own evidence, not on the weakness of the bank's. Her evidence failed. The certification she presented did not mention either title and, by her own witness's testimony, had no relation to the subject property. The errors in the bank's title were shown to be mere typographical errors that did not invalidate it. The bank, meanwhile, presented the decree of registration on which its title was based, and the decree and the title bore the same land registration case number and record number. The evidence therefore preponderated in favor of the bank.

On the second issue, the Court held that the trial court did not err in annulling Mayormita's title. Her title showed that it emanated from a decree, yet she failed to present that decree. Her own witness testified that no application for registration and no decree existed for the plan behind her title. The Court also rejected her claim that the annulment was a prohibited collateral attack, holding that an action for quieting of title is equivalent to an action for reconveyance, and that its successful outcome necessarily entails the cancellation of a title wrongly issued to another. The Court added that the trial court found no bad faith on the bank's part, and that an adverse title had existed since 1985 yet Mayormita questioned it only after nineteen years.

Doctrine

First, in a civil case the plaintiff bears the burden of proving the affirmative of the issue by preponderance of evidence, and must rely on the strength of his own evidence and not on the weakness of the defendant's. Second, a certificate of title that cannot be traced to a decree of registration, where the plaintiff fails to present that decree, is spurious and void. Third, typographical errors in a certificate of title do not invalidate the title. Fourth, bad faith is not presumed and must be proved by the party alleging it. Fifth, an action for quieting of title is equivalent to an action for reconveyance, and may result in the cancellation of a title wrongly issued to another.

Disposition

The Supreme Court affirmed the amended decision of the trial court, so the bank prevailed: Mayormita's complaint was dismissed and her certificate of title was annulled and ordered cancelled.

Remember This

Memorize this line: the plaintiff in a quieting of title must stand on the strength of his own title, and a title unsupported by a decree of registration is spurious. Examiners use this case to test burden of proof and preponderance of evidence in civil cases, the effect of typographical errors on a Torrens title, and whether a quieting of title amounts to a collateral attack.