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CLT REALTY DEVELOPMENT CORPORATION, Petitioner, v. HI-GRADE FEEDS
CORPORATION, REPUBLIC OF THE PHILIPPINES (THROUGH THE OFFICE OF THE SOLICITOR
GENERAL), REGISTRY OF DEEDS OF METRO MANILA, DISTRICT III, CALOOCAN CITY , AND THE
COURT OF APPEALS, Respondents.
G.R. No. 160684, September 02, 2015
PEREZ, J.:
Topic: JUDICIAL NOTICE
FACTS:
The properties in dispute were formerly part of the notorious Maysilo Estate left by
Gonzalo Tuason, the vastness of which measures 1,660.26 hectares, stretching across
Caloocan City, Valenzuela, and Malabon, covered by five (5) mother titles or Original
Certificate of Title (OCT). One of the mother titles is OCT No. 994, the mother title in dispute.
Later on, smaller lots forming part of the Maysilo Estate were sold to different persons.
Several subsequent subdivisions, consolidations, and one expropriation of the Estate, spawned
numerous legal disputes, living-up to the name "Land of Caveat Emptor." One of these
disputed lots was Lot 26, the property subject of this litigation. The conflict arose due to
an overlapping of the properties of CLT and Hi-Grade, which prompted CLT to file a case for
Annulment of Transfer Certificates of Title, Recovery of Possession, and Damages before the
Regional Trial Court against Hi-Grade.
The mother title is OCT 994. The arguments of the parties come from apparently the same
document. Notably, however, the parties' OCTs No. 994 contain different dates of registration,
namely: CLT's OCT No. 994 is dated 19 April 1917. While, Hi-Grade's OCT No. 994 is dated 3 May
1917.
RTC ruled in favor of CLT. According to the RTC, Hi-Grade's title, the older title, cannot
prevail over CLT's title because it suffers from patent defects and infirmities. Although
Hi-Grade paid realty taxes on the subject properties, it is not considered as a conclusive
proof of ownership. Hi-Grade elevated the case to the Court of Appeals. During the
pendency of the appeal, Hi-Grade filed a Motion to Admit and Take Judicial Notice of
Committee Report on Senate Inquiry into Maysilo Estate Submitted by the Committees on
Justice and Human Rights and on Urban Planning, Housing and Resettlement (Senate Report). CA
granted the motion. CA reversed RTC decision and ruled as baseless the trial court's
reliance on the testimonies of CLT's witnesses, on the alleged patent infirmities and
defects in the TCT. Also, the witnesses are incompetent to testify on the customary practices in
land registration at that time. Hence, this Petition for Review on Certiorari.
ISSUE/s: 1. Whether or not the Court of Appeals committed a reversible error when it took
judicial notice of the Senate Report. NO.
2. Which off the OCTs 994, that dated 19 April 1917 or that dated 3 May 1917, is the valid title?
HELD: WHEREFORE, the petition is hereby DISMISSED. The Decision and Resolution of the
CA are hereby AFFIRMED.
First Issue: Taking judicial notice of acts of the Senate is well within the ambit of the law.
Section 1 of Rule 129 of the Revised Rules on Evidence provides:
SECTION 1 . Judicial notice, when mandatory. — A court shall take judicial notice, without
the introduction of evidence, of the existence and territorial extent of states, their political
history, forms of government and symbols of nationality, the law of nations, the admiralty and
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maritime courts of the world and their seals, the political constitution and history of the
Philippines, the official acts of legislative,….
The Senate Report, an official act of the legislative department, may be taken judicial
notice of. The Senate Report shall not be conclusive upon the courts, but will be examined and
evaluated based on its probative value.
Second Issue: A title can only have one date of registration, as there can only be one title
covering the same property. The date of registration is reckoned from the time of the title's
transcription in the record book of the Registry of Deeds. Therefore, the date appearing on
the face of a title refers to the date of issuance of the decree of registration.
Based on Land Registration, the decree registering OCT No. 994, the date of the issuance is
19 April 1917 while on the other hand, OCT No. 994 was received for transcription by the
Register of Deeds on 3 May 1917. In this case, the date which should be reckoned as the
date of registration of the title is the date when the mother title was received for
transcription, 3 May 1917.
Therefore, as the date of transcription in the record book of the Registry of Deeds is 3 May 1917,
the genuine title is the title of Hi-Grade.
Any title that traces its source to a void title, is also void. The spring cannot rise higher than its
source. Nemo potest plus juris ad alium transferre quam ipse habet. All titles that trace its source
to OCT No. 994 dated 19 April 1917, are therefore void, for such mother title is inexistent. CLT so
traces its title to OCT No. 994 dated 19 April 1917, the title of CLT is void.
– D. Cogay
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