Facts:

The case involves Mercedita C. Coombs (petitioner) against several respondents, including Victoria Castañeda, Virgilio Veloso Santos, spouses Pancho and Edith Leviste, BPI Family Savings Bank, and the Register of Deeds of Muntinlupa City. The events leading to this case began when Coombs, the owner of a real property covered by Transfer Certificate of Title (TCT) No. 6715 located on Apitong Street, Ayala Alabang, Muntinlupa City, attempted to pay her real property tax in March 2005. She was informed that the property was no longer listed under her name. Upon investigation, she discovered that TCT No. 6715 had been cancelled and replaced by TCT No. 14115, issued in the name of respondent Virgilio Veloso Santos. The cancellation of TCT No. 6715 was based on a Regional Trial Court (RTC) decision dated August 26, 2004, in LRC Case No. 04-035, which Coombs claimed she had no knowledge of and did not authorize Castañeda to file for a second owner's duplicate copy of the title. ...

Facts:

Ownership and Discovery of Issue:

• Petitioner Mercedita C. Coombs (Coombs) owned a real property covered by Transfer Certificate of Title (TCT) No. 6715 located in Ayala Alabang, Muntinlupa City.
• In March 2005, Coombs discovered that the property was no longer listed under her name when she attempted to pay real property taxes. Upon further inquiry, she learned that TCT No. 6715 had been canceled and replaced by TCT No. 14115, issued in the name of respondent Virgilio Veloso Santos (Santos).

Unauthorized Actions:

• Coombs claimed that she never authorized Victoria C. Castañeda (Castañeda) to file a petition for the issuance of a second owner's duplicate copy of TCT No. 6715 in 2004, nor did she authorize the sale of the property to Santos.
• Santos subsequently sold the property to respondents Pancho and Edith Leviste (spouses Leviste), who then mortgaged it to respondent BPI Family Savings Bank (BPI Family).

RTC Decision:

• The Regional Trial Court (RTC) of Muntinlupa City, in LRC Case No. 04-035, declared the lost owner's duplicate copy of TCT No. 6715 null and void and ordered the issuance of a new duplicate copy. Coombs argued that the RTC lacked jurisdiction because the original TCT was never lost and remained in her possession.

Court of Appeals Ruling:

• The Court of Appeals dismissed Coombs' petition for annulment of judgment, citing procedural deficiencies, including the failure to allege extrinsic fraud properly and the failure to append necessary documents.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Jurisdiction Over Reconstitution Proceedings:

   • The RTC's jurisdiction in reconstitution cases depends on the fact of loss or destruction of the owner's duplicate copy of the title. If the title is not lost, the court lacks jurisdiction to order its reconstitution.
   • Coombs' possession of the original TCT negated the RTC's jurisdiction, rendering its decision void.

2. Annulment of Judgment Based on Lack of Jurisdiction:

   • A judgment rendered without jurisdiction is void and may be challenged at any time, unless laches applies.
   • Coombs' petition was properly grounded on lack of jurisdiction, and the Court of Appeals erred in dismissing it based on procedural technicalities.

3. Substantial Compliance with Procedural Requirements:

   • Coombs attached sufficient documents to support her petition, including the original TCT and the RTC Decision. These documents established a prima facie case for annulment.
   • The Court emphasized that technical rules should not be used to defeat substantive justice, especially when the judgment sought to be annulled is void for lack of jurisdiction.

Conclusion:

The Supreme Court granted Coombs' petition, set aside the Court of Appeals' Resolutions, and directed the reinstatement of her petition for annulment of judgment. The Court held that the RTC lacked jurisdiction over LRC Case No. 04-035 because the owner's duplicate copy of TCT No. 6715 was never lost, rendering its decision void. Coombs' petition was deemed sufficient in substance, and the Court of Appeals erred in dismissing it based on procedural grounds.