Facts:

This case involves a petition for review on certiorari by Virgil T. Aquino, Nazaria T. Aquino, Avelina A. Ronquillo, Patrocinio T. Aquino, and Ramoncito T. Nepomuceno (hereinafter referred to as "petitioner" or "petitioners") against the Estate of Tomas B. Aguirre (hereinafter referred to as "respondent"). The legal battle began in 2009 when the petitioners filed LRC Case No. 8843-2009-59 at the Regional Trial Court (RTC) in Bacoor, Cavite, requesting the reconstitution of the lost title of their parents’ property, specifically Transfer Certificate of Title (TCT) No. T-3269.

On March 21, 2014, the RTC granted the petition, recognizing the petitioners as the rightful heirs of the property, which measured approximately 300,824 square meters. The court noted that the original title of the subject property was lost, and that the necessary documentation presented by the petitioners justified the reconstitution. However, the respondent contested the recon

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Facts:

Background and Initiation

• In 2009, petitioners (relatives of Basilio Aquino and Ambrocia Tantay) filed LRC Case No. 8843-2009-59 for the judicial reconstitution of the lost original copy of Transfer Certificate of Title (TCT) No. T-3269.
• The petition was based on the owner’s duplicate copy of the title, asserting that the original was missing from the Registry of Deeds in Cavite.
• Petitioners have been in possession of the subject property—a parcel in Bacoor, Cavite measuring 300,824 square meters—since the 1930s.

Judicial Proceedings at the Trial Court

• On March 21, 2014, the Regional Trial Court (RTC) issued an Order that:
• Recognized petitioners as the children of Basilio Aquino and Ambrocia Tantay.
• Decreed the reconstitution of the lost original TCT No. T-3269 based on the owner's duplicate copy.
• Verified that the technical description of the property, as shown on the TCT, was accurate, having been compared with a Report from the Land Registration Authority (LRA).
• Notwithstanding the reconstitution order, there were evidences that the original may have been replaced or superseded by another title.

The Conflict of Titles

• The respondent, Estate of Tomas B. Aguirre, raised an objection by filing an Urgent Motion to Lift the Order of General Default on the basis that:
• The property was allegedly covered not only by the petitioners’ TCT No. T-3269 but also by another certificate of title, TCT No. T-6874.
• A Register of Deeds’ Manifestation dated April 1, 2014, indicated the existence of the competing title.
• The RTC, however, denied the respondent’s motions and proceeded with the reconstitution process.

Court of Appeals Rulings

• Before the motion for reconsideration of the RTC’s denial could be fully resolved, the respondent filed a Petition for Annulment of Judgment with reliefs meant to:
• Contest the jurisdiction and due process of the reconstitution proceedings.
• Assert extrinsic fraud based on the petitioner estate’s exclusion from the proceedings.
• On December 7, 2015, the Court of Appeals (CA) issued a Decision annulling the RTC’s order, holding that:
• Extrinsic fraud was present since petitioners were kept away from the proceedings.
• There was a lack of jurisdiction on the part of the RTC, as proper notice and procedural requirements were not observed.
• The CA, in a subsequent May 15, 2017 Resolution, kept its original holding, which led to the present petition before the Supreme Court.

Contentions of the Parties

• Petitioners claimed:
• The RTC had jurisdiction because their title was based on the owner’s duplicate copy.
• The technical description of the property was appropriate and verified by the LRA.
• The competing title (TCT No. T-6874) was irregular as it was issued later, and thus, petitioners’ title should prevail.
• They complied with all necessary legal requirements for reconstitution, negating any need for additional notice to occupants or adjoining lot owners.
• Respondent argued (though without submitting written comments to the Supreme Court):
• That the proceedings featured extrinsic fraud and were marred by procedural deficiencies.
• That the petition was premature since other remedies (motion for reconsideration and appeal) were available.
• That the competing title was substantiated by requirements under Republic Act No. 26.
• That procedural rules under both Sections 12 and 13 of R.A. No. 26 applied, mandating notice to all affected and interested parties.

Issue:

• Whether the trial court’s order directing the reconstitution of TCT No. T-3269 should be annulled due to the alleged extrinsic fraud and lack of jurisdiction.
• Whether the petition for annulment was premature given the availability of other remedies (motion for reconsideration and appeal).
• Whether the reconstitution proceedings violated the mandatory procedural and jurisdictional requirements under Republic Act No. 26, especially concerning the conflicting existence of TCT No. T-6874.
• Whether the non-notification of the petitioner estate and other interested parties constituted extrinsic fraud sufficient to invalidate the RTC’s decision.
• Whether the conflict between the two certificates of title (TCT No. T-3269 and TCT No. T-6874) should be resolved in favor of the earlier registered title based on the principle of primus tempore, potior jure.
• Whether the actions of certain legal representatives (such as the participation of M.A. Aguinaldo & Associates) amounted to an usurpation of authority in representing the parties involved.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)