Apr 282 min read

REGISTRATION; NOT A MODE OF ACQUIRING OWNERSHIP - SC

While a certificate of title serves as evidence of an indefeasible and incontrovertible title to the property in favor of the person whose name appears therein, it is not a conclusive proof of ownership, but merely confirms or records title already existing and vested.¹ In Spouses Yu Hwa Ping and Gaw v. Ayala Land, Inc., the Court explained the principle as follows:

Questions & Answers of 2005-2021 Supreme Court Decisions in Civil Law (2022 Edition)

"It is a well-settled rule that ownership is different from a certificate of title. The fact that a person was able to secure a title in his name does not operate to vest ownership upon him of the subject land. Registration of a piece of land under the Torrens System does not create or vest title, because it is not a mode of acquiring ownership."

Bar Q & A: Civil Law (2024) by Dean Viviana Martin-Paguirigan - Trade Paperback - Academic

A certificate of title is merely an evidence of ownership or title over the particular property described therein. It cannot be used to protect a usurper from the true owner; nor can it be used as a shield for the commission of fraud; neither does it permit one to enrich himself at the expense of others. Its issuance in favor of a particular person does not foreclose the possibility that the real property may be co-owned with persons not named in the certificate, or that it may be held in trust for another person by the registered owner.²