Heirs of Miguel Franco v. Court of Appeals

Summary

The Supreme Court affirmed the Court of Appeals' decision ordering cancellation of Miguel Franco's title to half of his deceased brother Quintin's property. Miguel had initially sworn in court that the entire 70.6381-hectare property belonged to Quintin when applying to be administrator of the estate. Four years later, Miguel claimed ownership of half the property based on a 'General Power of Administration' document and obtained a transfer certificate of title through suspicious proceedings that took only four days. The Court found this constituted fraud, emphasizing that Miguel's earlier sworn statement was both a declaration against interest and judicial admission that bound him. The Court rejected arguments that a trust relationship existed, noting the Civil Code provision on trusts by operation of law required joint purchase, which was absent since Quintin acquired the property through patent application alone. The decision reinforces principles of the Torrens system, evidentiary weight of judicial admissions, and protection against fraudulent title registration.