CARPOS V AYALA LAND

Short version: Carpos and Ayala are fighting over a parcel of land because Carpos claims that Ayalas TCT
are overlapping Carpos TCT. Ayala alleges that it derived its title over the land through OCT 242, issued in
1950. Meanwhile, Carpos TCT derived its title over the land through OCT 8575, issued only in 1970. Ayala
claims that its title should have priority since its derivative title was registered first. Carpos claimed that OCT
242 was void due to the lack of an approved survey plan by the Bureau of Lands. RTC ruled in favor of the
petitioners. CA reversed it. SC affirmed decision of CA. SC held that RTC was sabog in finding that the
survey plan was not approved because the annotation (that the title was issued with an approved survey
plan) was in the technical part of the title. Since it was found that OCT 242 was valid, plus the fact that it was
registered first, ALIs title shall be given priority.
FACTS:
Petitioner spouses (Soccoro and Morris) filed a complaint for Quieting of Title against Ayala Corp. Spouses
claimed to be the owners of a certain parcel of land covered by TCT 296463. They allege that Ayala Corp
was claiming to have TCTs (under different numbers, the most important TCT no. is T-5333) over the land
and Ayala made the property its equity contribution in Ayala Property Ventures Corporation. Said parcel
was to be developed into a residential subdivision.
Spouses Carpos claim that Ayalas TCTs covered a portion of the Carpos property during registered and
already indefeasible and incontrovertible. Therefore, they claim that Ayalas TCTs were invalid. They also
applied a write of preliminary injuction to enjoin respondent from doing its development work.
Spouses pray that the Ayala TCTs be canceled, and TCT 296463 be declared as their property.
Before the respondents could reply, spouses amended the complaint by replacing Ayala Corp with Ayala
Land, Inc. (ALI).
ALI contends that Ayala Copr merged with the former, and therefore, it no longer exists. Further, it alleges
that:
ALIs TCTs did not overlap with the Carpos parcel of land.
ALIs TCT no. T-5333 was derived from the Original Certificate of Title No. 242 issued in 1950,
while the Carpos TCT was derived from OCT No. 8575 issued only in 1970.
During the pendency of the case, ALI secured a title in its own name over the property covered by TCT No.
T-5333.
Makati RTC, where the case was originally filed, transferred the case to RTC Las Pinas where the land was
located.
ALI filed for a Motion for Summary Judgement, contending that the issue of the case was only a legal one
(which of the two titles should be accorded priority). ALI says its TCT should be given priority since OCT
242 was issued earlier than OCT 8575. This motion was denied, and was brought to the CA through a
petition for ceritiorari.
Unimportant procedural crap: CA granted motion for summary judgement. Both parties moved for
reconsideration, but both was denied by the CA
Went up to the SC but was only rendered a minute resolution (wawa naman sila). Petitions were actually
denied
RTC held that the Carpos OCT was superior to ALI. RTC said that ALI failed to alleged that OCT
242s survey plan was approved by the Director of Bureau of Lands. Original land registration
cases require that survey plans be approved by the Director of Bureau of Lands. No approved
survey plan = dubious title of origin. ALIs presentation of evidence showed that the survey plan of
OCT 242 did not had a sign of approval. Therefore, RTC was inclined to decide that the Carpos title
was more superior.
Further, ALIs TCT was surveyed on July 28, 1930. Carpos TCT was surveyed January 4-6, 1927.
This means Carpos predecessor-in-interest has claimed possession ahead of ALIs predecessorin-interest.

 The principle of prior registration cannot be applied because the land cannot be subjected to two
surveys. This may be the reason why the survey plan of ALIs OCT did not bear a sign of approval
because it was already surveyed before.
Unimportant procedural crap: ALI appealed but was denied due to failure to pay full amount of docket fees
CA reversed the RTC decision. Carpos appealed but was denied. Hence, this petition.
SC clarifications before discussing the issues:
RTC cancelled ALIs TCTs covering Carpos TCTs due to the lack of evidence of the identity of the land
described therein. This was a grievous and palpable error on the RTC considering that Carpos TCT had
a smaller area compared to the aggregate areas in the cancelled ALI TCTs.
A Geodetic engineer made a study on the lands covered by TCT 296463 and T-5333, and it was shown
that the lots did overlap. All other ALI TCTs did not overlap the Carpos TCT. RTC had no basis to
invalidate all other ALI TCTs.

ISSUES/HELD:
1. W/N the CA erred in validating the ALI TCT valid when the derivative OCT did not include an
approved survey plan. NO.
Petitioners clearly misunderstood or deliberately misread the CAs ruling on this point. It is the CAs view
that the trial courts pronouncement that OCT No. 242 was issued without an approved survey plan was
unwarranted in view of the presumption of regularity that said title enjoys.
To begin with, a perusal of the defendants answer or amended answer would show that, contrary to the
trial courts allusions thereto, there is no admission on the part of ALI that OCT No. 242 was issued
without a survey plan that was duly approved by the Director of the Bureau of Lands. There is likewise no
evidence on record to support the trial courts finding that the survey plan submitted to support the
issuance of OCT No. 242 in the 1950 land registration proceedings was approved only by the Land
Registration Commissioner and not by the Director of the Bureau of Lands.
It would appear the trial court came to the conclusion that OCT No. 242 was issued without a duly
approved survey plan simply because the notation SWO appeared in the technical description of the said
title which was attached to the answer and due to ALIs failure to allege in its pleadings that the survey
plan submitted in support of the issuance of OCT No. 242 was approved by the Director of the Bureau of
Lands.
It is incomprehensible how the trial court could conclude that the survey plan mentioned in OCT No. 242
was unapproved by the appropriate authority all from the notation SWO which appeared beside the
survey plan number on the face of the title or from a failure to allege on the part of ALI that a duly
approved survey plan exists.
OCT 242 was a result of the registration decree of the CFI of Rizal. In absence of proof to the contrary,
all ALI TCTs, including the derivative title, enjoy the presumption of regularity and ALI need not allege of
prove that its title was regularly issued.
Petitioner already alleged everything that would support the validity of their title. However, they did not
allege that the lack of the survey plan would invalided ALIs titles. They only relied on the priority of
their title.
Therefore, the sole issue is whose title will be given more priority? ALI SHALL BE GIVEN
PRIORITY.
where two certificates of title purport to include the same land, whether wholly or partly, the
better approach is to trace the original certificates from which the certificates of title were
derived.
2. W/N the action is already barred by laches and prescription. YES

 Petitioners say that their cause of action cannot be barred by prescription because the title in contention
was a VOID title. Therefore, such action cannot prescribe. However, the RTC ruled that the title was void
due to lack of evidence.
SC agrees with CA:
Aside from the fact that OCT No. 242 had become incontrovertible after the lapse of one (1) year from
the time a decree of registration was issued, any action for reconveyance that plaintiffs appellees could
have availed of is also barred.
It is now well settled that an action for reconveyance, which is a legal remedy granted to a landowner
whose property has been wrongfully or erroneously registered in anothers name, must be filed within
ten years from the issuance of the title, since such issuance operates as a constructive notice. Since
ALIs title is traced to an OCT issued in 1950, the tenyear prescriptive period expired in 1960.
Also, it took the petitioners 45 years to file an action. It would be unfair to the respondents if such action
would be entertained, given the ALI was an innocent purchaser for value.
Other assignments of error were just about the SC knit-picking on the way the RTC decided. Inaway
lang nila yung RTC. SC said the the RTC relied heavily on the admission of ALI regarding the validity
of Carpos title. However, it was discovered that nowhere in ALIs statement that they admitted the
validity of Carpos title. Another error was the issue on res judicata. CA discovered another derivative
title covered in another case (Guico v San Pedro) that was connected to the TCTs in contention. CA
said there was already res judicata because the basis of ALIs TCTs were settled in Guico (meaning
na-settle na yung issues ng OCT 242 so dapat di na siya iopen ulit).