Petitioner
Milagros Tumulak Bishop
Respondent
Honorable Court of Appeals
Citation
G.R. No. 86787
Court
Supreme Court
Division
First Division
Ponente
Cruz, J.
Decided
May 8, 1992

Summary

This case involves a property dispute where registered landowners Spouses Salang sought to recover possession of their titled land from multiple occupants. The petitioners claimed the 1,652 square meter property in Zambales was public domain and asserted rights through long possession, tax declarations, and some through contracts of sale and inheritance. The Supreme Court unanimously denied the petition, reaffirming fundamental Torrens system principles. The Court held that land registered under the Torrens system cannot become public domain again and that such titles are incontrovertible after the statutory period. The decision emphasized that registered owners have an imprescriptible right to eject unauthorized occupants, regardless of the length of possession, and that acquisitive prescription cannot apply to registered land. The case reinforces the integrity and indefeasibility of Torrens titles.

Intellegal Wiki · Key Holding

An Original Certificate of Title is incontrovertible after the one-year period, and under the Torrens system registered land cannot be lost to acquisitive prescription — the registered owner's right to eject occupants is imprescriptible.

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By the Intellegal Editorial Board · May 8, 1992

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