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.
