G.R. No. 120600 - Dawson vs. Register of Deeds of Quezon City

On May 2, 1967, Louis P. Dawson entered into a contract to sell with Siska Development Corporation for a parcel of land in Quezon City, covering 638 square meters, at a contract price of P27,632.00.
The contract was on an installment basis, typical of a contract to sell, whereby ownership (title) does not transfer until full payment of the consideration.

On June 3, 1971, Louis P. Dawson died intestate, leaving the contract unresolved with incomplete installment payments.
Following his death, his heirs (the petitioners) assumed his rights and obligations under the contract, proceeding to settle the remaining payments from their own funds.
The full payment was completed in 1978, yet the title over the property had not vested in Louis P. Dawson, the original vendee.

In an apparent mistake, Siska Development Corporation executed a deed of absolute sale on March 16, 1978, in favor of the deceased Louis P. Dawson—even though he had been dead for seven years—rather than in favor of his heirs.
Consequently, Transfer Certificate of Title (TCT) No. RT-58706 (248057) was issued in the name of Louis P. Dawson instead of the petitioners, who had fully paid the contract price.
The petitioners sought relief by filing a petition for cancellation and correction of the TCT pursuant to Section 108 of Presidential Decree (PD) 1529, claiming that the error was manifest.

On October 7, 1993, the petitioners filed the petition with the Regional Trial Court in Quezon City, including requests for cancellation of the title in the name of Louis P. Dawson and its reissuance in the names of the petitioners in specified shares.
The trial court allowed the petitioners to present their evidence ex parte, and on December 20, 1993, issued a resolution dismissing the petition (later affirmed by the Court of Appeals).
A motion for reconsideration was filed on February 2, 1993, but was denied by a subsequent court order dated March 21, 1994, leading to the petition for review.

Whether Section 108 of PD 1529, which provides for summary proceedings for the amendment, cancellation, or alteration of a certificate of title, is applicable in the present case involving the erroneous issuance of a title in the name of a deceased vendee.
Whether the petitioners, as heirs who assumed the deceased’s contractual obligations and completed the payment, are entitled to have the title corrected to reflect their true ownership, or if the issue is merely one of partition of the deceased’s estate.