G.R. No. 175788 - Enriquita Angat and Legal Heirs of Federico Angat vs. Republic

Enriquita Angat and the legal heirs of Federico Angat filed a verified petition for reconstitution of the original copy of Transfer Certificate of Title (TCT) No. T-4399.
The title covered a 3,033,846-square meter parcel of land located in Sapang, Ternate, Cavite.
The subject property was originally registered under TCT No. T-4399 in their names since October 6, 1955.

The old Provincial Capitol Building housing the Registry of Deeds of Cavite was burned on June 7, 1959, which destroyed all titles and documents, including the original TCT No. T-4399.
Petitioners possessed the owner’s duplicate copy of the TCT, which was intact and never delivered to a third party or involved in any transaction or encumbrance.

Petitioners filed the petition with the RTC, which set the initial hearing and complied with publication and posting requirements.
Notices were sent via registered mail to adjoining property owners as per the 1930 survey plan; however, all notices were returned unserved due to various reasons (unlocated, deceased, or refused).
The Office of the Solicitor General (OSG) entered its appearance to represent the Republic.

Petitioners presented various documentary evidence including the petition, court order, certificate of publication, certifications from the Register of Deeds and Land Registration Authority (LRA), and survey plans.
The Registry of Deeds certified the non-existence of the original TCT in its records due to the fire.
The LRA submitted reports verifying the technical description of the property but noted discrepancies in initial submissions.
Federico testified regarding possession and ownership history, asserting that the title was inherited from the grandfather through the father, and claimed possession since 1955.

Ternate Development Corporation (TDC) moved to intervene, claiming ownership of a portion of the property under a different TCT.
The RTC denied TDC’s motion, holding that the reconstitution proceeding was not the proper forum to challenge title validity.
RTC granted the petition for reconstitution on November 27, 2000, ordering the Register of Deeds to reconstitute the original TCT.

The Republic appealed, arguing lack of jurisdiction due to failure to notify adjoining owners and failure of petitioners to prove valid ownership.
The Court of Appeals reversed the RTC, dismissing the petition for lack of jurisdiction because notices to adjoining owners were unserved and the ownership claim was inadequately proven.
The Court of Appeals decision became final and executory after petitioners failed to timely file a motion for reconsideration.

They argued that notice to adjoining owners was not required when reconstitution is based on the owner’s duplicate title, citing jurisprudence.
Claimed substantial compliance with notice requirements.

Whether the Court of Appeals erred in dismissing the petition for reconstitution.
Whether the Court of Appeals erred in requiring notice to adjoining owners.
Whether the Court of Appeals acted in excess of jurisdiction regarding applicable law (RA 26).

Did the Court of Appeals err in dismissing the petition for reconstitution on the grounds cited by the OSG in the appeal?
Did the Court of Appeals err in imposing the requirement of notifying adjoining owners despite the petitioners’ substantial compliance with the trial court’s requirements?
Did the Court of Appeals act in excess of jurisdiction by not applying the correct law (Republic Act No. 26, Sections 2 and 3) concerning reconstitution based on owner’s duplicate titles?