HWA PING v.

AYALA LAND [166577 & 173141]

Facts:

- Spouses Diaz submitted to the General Land Registration Office a survey plan for the approval of
the Director of Lands covering a parcel of land in Rizal (March 17, 1921).
o Another survey plan was also done for a certain Dominador Mayuga, covering Lot 3 on
the same land, but the location was different; Sitio May Kokek instead of Sitio Kay
Monica, Barrio Almanza instead of Barrio Pugad Lawin (October 21, 1925).
o Another survey was again made for a certain Eduardo C. Guico which then indicated
another different address (July 28, 1930).
o A total of 4 different surveys were made as one was also done on March 6, 1931 by
Yaptinchay.
- OCT’s were issued to the others who conducted a survey, and some of the properties were sold
to CPJ Corporation.
- Spouses Diaz were granted original registration of the property and later subdivided it to 10 lots;
CPJ Corporation filed against Spouses Diaz seeking to review the 10 subdivided lots on the
ground that interested persons were not notified of the application.
o On March 1993, Spouses Yu (Hwa Ping and Mary) acquired ownership over one of
Spouses Diaz’s lots.
o On the other hand, CPJ Corporation transferred their interest to third persons which
Ayala Land was then able to obtain.
- RTC ruled against Spouses Diaz saying that the latter committed fraud when they applied for
original registration for not informing interested parties.
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- Meanwhile, Spouses Yu visited their lots and discovered that Ayala Land Inc. was occupying it;
Spouses Yu filed against Ayala for declaration of nullity of TCTs and recovery.
- RTC ruled in favor of Spouses Yu saying the titles of Ayala were secured through fraud.
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- CA’s decision
o Ruled in favor of Ayala in the Diaz case, as the latter committed fraud for not informing
interested parties.
o Ruled in favor of Ayala in the Yu case, as the 1-year period to contest the title of Ayala
has already prescribed, hence incontestable.
o Losing parties filed for reconsideration, granted. Ayala also filed another motion for
reconsideration, also granted; Spouses Diaz and Spouses Yu appealed.

ISSUES:

- WON the Complaint of Spouses Yu is barred by prescription

- WON the validity of the surveys can be assailed
- WON the case of Guico v. San Pedro is applicable
- WON the errors of the aforementioned registrations would invalidate their TCTs
 RULING:

- No. While it is true that questioning the registration must be done within 1 year, it is not the only
remedy of an aggrieved party deprived by fraudulent means, as he may still avail of the remedy
of reconveyance in an ordinary action (constructive trust which prescribes 10 years from
registration; or imprescriptible if the movant is in actual possession).
o In the case at bar, Spouses Yu’s actions were for reconveyance due to Ayala’s continued
possession of their property.
- Yes, as there were anomalies in the manner of doing so.
o As to the property of Diaz, the Court ruled that it bore all the hallmarks of verity as it
contains the signautres of the surveyor and the Director of Lands, and did not contain
any erasure or alterations. Also, a duly authenticated copy of it (PSU-25909) is available
in the Bureau of Lands.
o As to the properties acquired by CPJ, the RTC correctly observed the irregularities in the
surveys:
▪ Being conducted despite already being covered by Diaz’s land
▪ Covered by the same surveyor on different instances and having different
addresses
▪ Ayala presented that it was done for a certain person but the certified true copy
says it was done for another
▪ Etc.
- Yes. The case of Guico laid out the concept that not being able to submit a valid and approved
plan will prevent registration. In the case at bar, the registration relied upon by CPJ were
premised on several anomalies, therefore preventing their ownership over the lands.
- Yes. When a land registration decree is marred by severe irregularity that discredits the integrity
of the Torrens system, the Court will not think twice in striking it down. Thus, due to numerous
errors, the properties relied upon by CPJ and later on Ayala were declared void. Diaz did not
commit fraud, as the properties acquired by Ayala are void; Diaz had no obligation to inform CPJ.