Angeles v.

Samia (1938)

Topic: Exception to the rule of quieting title to registered land

Facts:
Disputed in this case is the ownership of a parcel of land. Said land in question was inherited by
the plaintiff from his father before the year 1896. Plaintiff possessed and occupied the land under
claim to ownership up to the present. He attempted to register his title to said land pursuant to the
Land Registration Act in 1909, but his application was denied due to errors in his plan. However,
he continued to exercise acts of ownership over it. In 1921, without plaintiff’s knowledge,
Original Certificate of Title No. 8995 was mistakenly issued in the name of defendant and her
three other co-participants: Macaria, Petra, and Felisberto, thereby mistakenly naming them as
the owners of the said land in question. That these co-owners, having decided to partition among
themselves the properties held by them in common, the said land was allotted only to defendant.
The plaintiff requested the defendant, inasmuch as it was through error that said land had been
adjudicated to her and her co-owners, to execute the corresponding deed of transfer in his favor,
the land being lawfully his.

Issue: W/N the original certificate of title should be cancelled.

Held: Yes.
The Court reasoned that the defendant and her co-owners knew or, at least, came to know that it
was through error that the original certificate of title was issued by the court in their favor. The
Land Registration Act protects only holders of a title in good faith and does not permit its
provisions be used as a shield for the commission of fraud or that one enriches himself at the
expense of another. If a person happens to obtain it by mistake, with or without bad faith on his
part, the certificate of title may and should be cancelled or corrected. It cannot be otherwise.