CASE DIGEST: Esmaquel vs. Coprada

G.R. No. 152423 : December 15, 2010




On February 24, 1997, spouses Esmaquel filed an ejectment case against Coprada before the 2nd MCTC Laguna. Petitioners claimed that they are the registered owners of a parcel of land situated in San Miguel, Majayja. In 1945, Coprada was able to persuade the petitioners to allow her and her family to use and occupy the land for their residence, under the condition that they will vacate the premises should petitioners need to use the same. Coprada and her family were allowed to construct their residential house. Since then, the petitioners never made an attempt to drive them away out of pity, knowing that respondent and her eight children have no other place to live in. the a few years later the financial condition of Copradas family, having acquired her own residential house. This prompted petitioners to institute an ejectment case against Coprada. Respondent avers that she had already acquired ownership over the contested lot when she orally purchased it. And further avers that the claim has already prescribed and thus barred by laches.

MCTC ruled in favor of Coprada, thus the case was dismissed. On appeal to the RTC, the ruling of the MCTC was reversed. The CA reversed the RTCs decision and reinstated the MCTCs ruling.

ISSUE: Whether or not petitioners have a valid ground to evict respondent from the subject property.



As a registered owner, petitioner has a right to eject any person illegally occupying his property. This right is imprescriptible and can never be barred by laches.

In the present case, Coprada failed to present evidence to substantiate her allegation that a portion of the land was sold to her in 1962. Coprada's submission that there was an oral sale is a mere afterthought.

On the other hand, it is undisputed that the subject property is covered by a title, registered in the name of the petitioners. As against the respondent's unproven claim that she acquired a portion of the property from the petitioners by virtue of an oral sale, the Torrens title of petitioners must prevail. Petitioners' title over the subject property is evidence of their ownership thereof. It is a fundamental principle in land registration that the certificate of title serves as evidence of an indefeasible and incontrovertible title to the property in favor of the person whose name appears therein. Moreover, the age-old rule is that the person who has a Torrens title over a land is entitled to possession thereof.

Further, Coprada's argument that petitioners are no longer the owners of a portion of the subject land because of the sale in her favor is a collateral attack on the title of the petitioners, which is not allowed. The validity of petitioners' certificate of title cannot be attacked by respondent in this case for ejectment. Under Section 48 of PD No. 1529, a certificate of title shall not be subject to collateral attack. It cannot be altered, modified or canceled, except in a direct proceeding for that purpose in accordance with law. The issue of the validity of the title of the petitioners can only be assailed in an action expressly instituted for that purpose. Whether or not the respondent has the right to claim ownership over the property is beyond the power of the trial court to determine in an action for unlawful detainer.

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