G.R. No. 163994 - Eastworld Motor Industries Corp. vs. Skunac Corp.

In February 2001, Miguel Lim, appearing as president of the respondent corporation, filed a petition before the Regional Trial Court (RTC), Branch 4, Manila.
The petition was for the issuance of a new transfer certificate of title (TCT No. 207104) in lieu of the allegedly lost owner’s duplicate certificate.
As jurisdictional requirements, an affidavit of loss was executed and a photocopy of the alleged title was attached.

On March 7, 2001, the trial court set the petition for an ex-parte reception of evidence, with proceedings scheduled and evidence taken on March 28, 2001.
On May 22, 2001, the RTC issued an order directing the Register of Deeds of Manila to issue a new owner’s duplicate of TCT No. 207104 and to deliver it to Miguel Lim or his authorized representative.
A certificate of finality was subsequently issued by the Land Registration Authority (LRA) on June 25, 2001.

A petition to annul the RTC order and for the issuance of a restraining injunction was forwarded to the Court of Appeals (CA).
The sole issue raised was whether the RTC’s order was null and void for lack of jurisdiction, on the ground that the owner’s duplicate was not truly lost but in the possession of Larry Lim, purportedly the president of the respondent corporation.

Respondent corporation argued that Miguel Lim’s affidavit contained a false statement, asserting that the owner’s duplicate certificate was lost when, in fact, Larry Lim was in possession of it.
It was contended that the issuance of the reconstituted duplicate certificate was based on fraudulent representations.
Petitioner Eastworld Motor Industries Corporation, represented by its chairman Peter Ty, intervened asserting its rights as an innocent purchaser for value, claiming that it had no notice of the irregularity and that it bore the loss due to respondent corporation’s actions.

Whether the Court of Appeals erred in declaring the reconstituted certificate of title null and void more than one (1) year after its issuance.

Whether the mere fact that the TCT 207104 in petition is a reconstituted title negates the status of petitioner as a purchaser in good faith and for value.

Whether the CA erred in dismissing petitioner’s intervention claiming good faith purchase.

Whether the nullification of the reconstituted title prejudices petitioner’s rights concerning the property.

Whether the CA erred in failing to note that Larry Lim’s negligent failure to update the corporation’s Securities and Exchange Commission (SEC) documents contributed to the occurrence of the defective title issue.