Case Digest (G.R. No. 206077)
Facts:
The case is Helen P. Denila v. Republic of the Philippines, City Government of Davao, et al., G.R. No. 206077, July 15, 2020, decided by the Supreme Court Third Division, Gesmundo, J., writing for the Court. Petitioner Helen P. Denila sought review of the Court of Appeals (CA) decision that granted the Republic’s petition for certiorari and set aside the Regional Trial Court (RTC), Branch 14, March 4, 2008 decision ordering reconstitution of several Original Certificates of Title (OCTs) in the name of Constancio S. Guzman, and its September 3 and October 1, 2009 orders.The dispute began with a series of reconstitution petitions filed in the RTC by heirs/candidates claiming lost or destroyed OCTs registered to Constancio Guzman and Isabel Luna. The RTC, through Judge George E. Omelio, granted petitioner Denila’s amended petition for reconstitution on March 4, 2008, ordering reconstitution and issuance of new Transfer Certificates of Title in Denila’s name. The Office of the Solicitor General (OSG) and the Republic contested the grant; the RTC clerk (Atty. Ray Uson Velasco) certified the decision as final and executory on March 28, 2008, and an Entry of Judgment followed on March 31, 2008.
The Republic, via the OSG, filed a Petition for Relief from Judgment in RTC on May 26, 2008. Judge Omelio voluntarily inhibited, the case was re-raffled, and ultimately Omelio re-assumed jurisdiction and summarily denied the Republic’s petition on September 3, 2009; his October 1, 2009 order denied reconsideration. The Republic filed a Rule 65 certiorari petition with the CA, which issued injunctive writs and eventually, on July 25, 2012, granted certiorari, voiding the RTC decision and orders. Multiple interventions followed: the City of Davao and numerous actual occupants (private respondents) sought to intervene claiming possessory interests and lack of notice. Denila sought review by this Court via a Rule 45 petition for review on certiora...(Subscriber-Only)
Issues:
- Was there grave abuse of discretion by the RTC in the September 3, 2009 Order that summarily denied the Republic’s Petition for Relief from Judgment?
- Was the CA correct to nullify the RTC’s March 4, 2008 Decision granting reconstitution of OCTs?
- Was it proper for the CA to admit and allow actual occupants (intervenors) to participate in the certiorari proceedings?
- Should disciplinary or administrative sanctions be imposed on counsel and court officers who ...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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