Castaneto v. Spouses Adame

 

Castaneto v. Spouses Adame

G.R. No. 248004

April 12, 2023

 

FACTS:

                On September 1995, Castaneto purchased, in good faith, from Sps. Tablada a parcel of land covered by TCT 206899. On December 1995, Sps. Adame acquired the 130sqm lot in good faith from Serain and purchased the adjacent 197 sqm land with TCT 224655. In which they have been in possession of since 1995. They subsequently mortgaged the property to Solid bank. They have built concrete fences and a warehouse on the property.

 

ISSUE:

                Whether Castaneto or Sps. Adames possess a validly issued certificate.

 

HELD:

                “Where two transfer certificates of title have been issued on different dates, to two different persons, for the same parcel of land even if both are presumed to be holders in good faith, it does not necessarily follow that he who holds earlier title should prevail. On the assumption that there was regularity in the registration leading to the eventual issuance of subject transfer certificates of title, the better approach is to trace the original certificates from which the certificates of title in dispute were derived. Should there be only one common original certificate of title, xxx, the transfer certificate issued on an earlier date along the line must prevail, absent any anomaly or irregularity tainting the process of registration."

                The party having the burden of proof must establish his case by preponderance of evidence, which is evidence of greater weight, or more convincing than that which is offered in opposition to it. Preponderance of evidence is the weight, credit, and value of the aggregate evidence on either side and is usually considered to be synonymous with the term "greater weight of evidence" or "greater weight of credible evidence." Failure to present a any verification survey of property is not fatal, as long as it is sufficiently established that the identity of property through boundaries and technical description is stated in his title. Castaneto’s title which describes the property, the location, area, and the boundaries thereof, is the most credible proof of the identity of her property and her ownership. In sum, because petitioner had proven that her title was regularly and validly issued, then she is entitled to the reliefs prayed for by her.