Facts:

The case involves the Acting Registrars of Land Titles and Deeds of Pasay City, Pasig, and Makati, Metro Manila as petitioners against the Regional Trial Court, Branch 57 in Makati, Metro Manila, presided over by Judge Francisco X. Velez, and the intestate estate of the late Delfin Casal, represented by Domingo C. Palomares, as respondents. The events leading to this case began on November 5, 1985, when Domingo Palomares, acting as the administrator of the heirs of Delfin Casal, filed a suit in the Regional Trial Court, Branch 132, Makati, for declaratory relief, quieting of title, and cancellation of Transfer Certificate of Title (TCT) No. 192, along with entries on Original Certificate of Title (OCT) No. 291. Earlier, on February 27, 1985, Palomares had petitioned the Supreme Court for a duplicate owner's copy of OCT No. 291, which was denied for lack of merit. The case involved a 2,574-hectare parcel of land known as Hacienda de Maricaban, located in various parts of M...

Facts:

Parties and Case Background

• The petitioners are the Acting Registrars of Land Titles and Deeds of Pasay City, Pasig, and Makati, while the private respondent is Domingo C. Palomares, acting as administrator for the intestate estate of the late Delfin Casal.
• The case involves a 2,574-hectare parcel of land known as Hacienda de Maricaban, which spans parts of Makati, Pasig, Taguig, Pasay City, and Paranaque.
• The dispute centers on the cancellation of Original Certificate of Title (OCT) No. 291 and whether private respondent Domingo Palomares was authorized to perform acts of ownership over the said land.

Chronology of Proceedings and Pleadings

• November 5, 1985 – Domingo Palomares, in his capacity as administrator of the heirs of Delfin Casal, commenced suit before the RTC, Branch 132, Makati, for declaratory relief, quieting of title, cancellation of Transfer Certificate of Title (TCT) No. 192, and cancellation of entries on OCT No. 291.
• Earlier, on February 27, 1985, Palomares had approached the Court on a similar petition seeking both declaratory relief and the issuance of a duplicate owner’s copy of OCT No. 291 in place of an allegedly lost original.
• September 9, 1985 – The petition for issuance of a duplicate copy was denied for lack of merit.
• December 19, 1985 – Petitioners responded with an answer, contesting the standing of the intestate estate as a juridical person and other technical and substantive issues.
• June 2, 1986 – The private respondent filed a motion to admit an amended complaint, impleading the Republic of the Philippines and the registers of deeds of Pasig, Makati, and Pasay City; alleging, among other things, that:
• On October 1, 1906, a Court of Land Registration confirmed the title of Dolores Pascual Casal y Ochoa over the property.
• Subsequent registrations transferred the title and, upon successive deaths, the property devolved to heirs bearing the Casal name.
• No conveyances or disposals had been effectuated upon the parcel; and offers a series of allegations regarding spurious documents, state interference, and damages incurred by the heirs.
• June 26, 1986 – Petitioners filed a counter-answer asserting:
• The intestate estate (or Delfin Casal’s estate) lacks capacity to sue as a juridical person.
• The registers of deeds are not the real parties in interest.
• The non-joinder of indispensable parties renders the suit fatally defective.
• OCT No. 291 had long been cancelled, pointing to a previous decision denying the issuance of a duplicate copy.
• The claims of the Casals were barred by res judicata and prescription, and were unable to override titles of innocent purchasers.
• August 29, 1986 – The respondent judge issued a temporary restraining order directing the petitioners to cease the allegedly unauthorized acts.
• October 12, 1987 – The RTC, Branch 57, presided over by Judge Francisco Velez, issued an order granting the private respondent relief under an omnibus motion. The relief included:
• Authorization for Domingo Palomares to order subdivision and individual surveys of certain parcels for efficient administration of the property exemplified in OCT No. 291.
• Permission to sell, exchange, lease, or otherwise dispose of any parts of the property (subject to the approval of the Intestate Estate Court) to cover taxes, administrative expenses, and for property protection.
• October 23, 1987 – A clarificatory order followed, affirming that the private respondent could execute the acts authorized by the October 12 order without requiring a separate Writ of Execution after the order became final.
• Subsequent Developments
• Petitioners filed a notice of appeal against the RTC orders, which was denied on the ground that the appeal was directed against an interlocutory order.
• The private respondent later sought certiorari in a related proceeding (G.R. No. 90176) regarding parcels disposed of by Judge Conrado Vasquez, Jr. in connection with another estate matter.
• Amid separate motions, supplemental comments, and interventions by counsel for the heirs of Delfin Casal, contentious questions of jurisdiction, validity of title, and the propriety of the orders emerged.

Core Controversies Raised

• Whether Original Certificate of Title No. 291 is still valid and subsisting despite allegations of cancellation.
• Whether Judge Velez, by issuing orders that effectively conveyed acts of ownership to the private respondent before trial and without notice to registered owners, committed grave abuse of discretion tantamount to a lack or excess of jurisdiction.
• Whether the RTC properly acquired jurisdiction over the subject matter and rendered proceedings res judicata in light of prior adjudications.

Issue:

• Is Original Certificate of Title (OCT) No. 291 still valid and subsisting, or has it been duly cancelled and rendered ineffective for the heirs of Delfin Casal?

Did the respondent judge (Judge Francisco Velez) commit grave abuse of discretion—amounting to a lack or excess of jurisdiction—by:

• Issuing an order before trial that authorized the private respondent to perform acts of ownership over the disputed land?
• Allowing Domingo Palomares to transact through subdivision, sale, or exchange of portions of the property without notice to the registered owner?
• Is the RTC’s decision, including the issuance of temporary and clarificatory orders, consistent with the proper exercise of judicial authority and jurisdiction given the non-joinder of indispensable parties and principles of res judicata?

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)